Compliance into the Weeds

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the question of whether a law degree is necessary for Chief Compliance Officers (CCOs). Tom and Matt begin with a discussion of a recent compensation survey by Barker Gilmore that reveals CCOs with law degrees earn significantly more than their counterparts without JDs. They explore historical and practical reasons for this pay disparity and debate the actual necessity of a law degree for fulfilling modern compliance functions. Additionally, they identify key skills and functions essential for effective compliance and consider alternative career paths and educational backgrounds suited for aspiring compliance professionals.Key Highlights·      The Value of a Law Degree for Compliance Officers·      Breaking Down the Pay Disparity·      Modern Compliance Demands·      Career Paths and Skills for Compliance OfficersResourcesMatt in Radical Compliance Tom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!In this episode, Tom Fox and Matt Kelly take a deep dive into the toxic workplace culture at Bank of America (BoA) around hours worked by junior employees, in spite of senior management saying the right things.BoA’s investment banking division has long been plagued by a toxic work culture, characterized by overworked junior employees and severe health crises, despite repeated assurances of reform. Tom Matt discuss these pervasive issues within BoA’s work environment. Fox highlights the tragic consequences of this toxic culture, such as the deaths of junior employees, and criticizes the company's failure to implement effective reforms, attributing this to a lack of accountability and ethical leadership. Kelly echoes this sentiment, emphasizing the necessity for senior management to set clear expectations and consequences for middle managers who perpetuate unethical behavior. Both stress the need for senior management to address the deep-seated cultural dysfunction, impose consequences, and foster a healthier, rule-abiding workplace to prevent further tragedies and promote employee well-being.Key Highlights: Toxic Workplace Culture at Bank of America Proactive Controls for Preventing Employee Overwork Consequences of Middle Managers in Corporate Culture Cultural Impact: Negative Attitudes in Organizations Resources:Matt in Radical ComplianceHow Bank of America Ignores Its Own Rules Meant to Prevent Dangerous Workloads, by Alexander Saeedy in the WSJ Tom InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!In this episode, Tom Fox and Matt Kelly take a deep dive into some of the nettlesome internal challenges faced by many Chief Compliance Officers (CCOs) in today’s corporate environment.On Compliance into the Weeds, Tom and Matt discuss the various challenges that CCOs face within organizations. They delve into stories of how senior management, particularly General Counsels (GCs) and Chief Financial Officers (CFOs), can sometimes undermine compliance efforts. The conversation explores issues such as budget cuts, restrictive vendor usage, structural impediments, passive-aggressive behaviors, and direct interference in investigations. They also consider potential solutions and strategies for CCOs to better navigate these struggles and ensure the effectiveness of compliance programs.Key Highlights: Budgetary Constraints and Sabotage Interference in Investigations Structural Impediments to Compliance Undermining by Engagement and Assignment Advice Going Forward Resources:Matt in Radical ComplianceTom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!In this episode, Tom Fox and Matt Kelly take a deep dive into the recently announced Department of Justice (DOJ) Whistleblower Incentive Program.Last week, the DOJ announced a whistleblower pilot program, offering monetary rewards to whistleblowers who report corporate misconduct. Whistleblowers can receive up to 30% of the net proceeds of a settlement resulting from their tip. The program covers various types of corporate crime, including bribery, healthcare fraud, and Foreign Corrupt Practices Act (FCPA) violations.This program puts pressure on compliance programs to quickly investigate and address reported misconduct. It also raises questions about how whistleblowers will be rewarded in cases where there is a declination or non-prosecution agreement. The SEC case involving a whistleblower award highlights the importance of handling whistleblower reports effectively.Key Highlights: DOJ Announces Whistleblower Pilot Program Covering Various Types of Corporate Misconduct Tension Between Self-Reporting and Whistleblower Reporting Recent SEC whistleblower award as a cautionary tale Resources:Matt in Radical Compliance TomInstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject.Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!In this episode Tom Fox and Matt Kelly take a deep dive into the Plea Agreement filed by the DOJ in the Boeing criminal case.Today we delve into the proposed plea agreement between the Department of Justice and Boeing, following violations of the company’s 2021 Deferred Prosecution Agreement (DPA). We discuss the detailed aspects of the plea, including a $243 million criminal penalty, a $455 million compliance investment plan, a three-year prosecutor probation with a compliance monitor, and a unique interaction between Boeing’s board and the families of crash victims.Matt and Tom also explore Boeing’s obligations to integrate safety and quality programs with its ethics and compliance initiatives, and the implications of these stringent new requirements.Key Highlights: Boeing’s Compliance and Safety Issues Expansion of Corporate Compliance Role Implications for Boeing’s Compliance Culture Monitor, Oversight, and Victim’s Families Role of the Board and Compliance Spending Future Considerations and CCO Certification Resources:Matt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog TomInstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!In this episode, Tom Fox and Matt Kelly take a deep dive into the dismissal of the SEC’s enforcement action against Solar Winds and CrowdStrike cybersecurity failures.Tom and Matt begin with UnitedHealth’s costly ransomware attack, a federal judge’s ruling against the SEC’s lawsuit over SolarWinds’ cybersecurity practices, and CrowdStrike’s flawed software update impacting global corporations.The episode explores the regulatory challenges of enforcing effective cybersecurity controls and the implications for companies and their compliance programs. The discussion highlights the need for better IT general controls and the role of different stakeholders, including Congress, regulatory agencies, and audit firms, in addressing these cybersecurity risks.Key Highlights: UnitedHealth Ransomware Attack Breakdown SolarWinds Cybersecurity Lawsuit Regulatory Challenges and Implications Operational Risk Management and IT Controls Call to Action for Compliance and Audit Professionals Resources:Matt on Radical Compliance Tom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!In this episode, Tom Fox and Matt Kelly take a deep dive into a recent SEC enforcement action involving RR Donnelley, where a cyber breach was characterized as an internal controlIn this episode, we discuss how criminal activities in cyberspace are outpacing regulatory measures and the law’s ability to keep up. The conversation touches on the idea that access controls for valuable corporate assets, whether financial data or sensitive information, are becoming indistinguishable in the eyes of cybercriminals. The discussion includes a thought-provoking perspective on merging cybersecurity and anti-money laundering functions, as both deal with improper electronic transactions. The core concern is not just the breach itself, but also the prevention of data exfiltration.Key Highlights: Corporate Jewels: Money vs. Data Cybersecurity and Anti-Money Laundering Improper Electronic Transactions Focus on Data Exfiltration Conclusion: Preventing Data Theft Resources:Matt on Radical Compliance Tom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive analyzing term-ending Supreme Court decisions from a compliance perspective. They address the Jarkesy decision on SEC in-house tribunals, the Loper ruling overturning the Chevron deference doctrine, and the Snyder decision that narrows the scope of federal anti-corruption law. Despite the headlines, they conclude that these rulings have minimal direct impact on corporate compliance programs, emphasizing the ongoing importance of ethical integrity and effective compliance practices.Key Highlights·      Supreme Court Cases Impacting Compliance·      The Jarkesy Decision: Minimal Impact on Compliance·      The Loper Case: Chevron Deference Overturned·      The Snyder Decision: A Controversial Ruling·      Implications and Final ThoughtsResourcesMatt on Radical Compliance Tom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the complexities surrounding the Department of Justice's potential decision to criminally prosecute Boeing under its Deferred Prosecution Agreement (DPA) related to the 737 MAX crashes. They explore the various facets of corporate justice, including retribution, remediation, and societal interests, as well as the challenges in balancing justice for the victims and the broader implications for public safety and corporate culture. The discussion also covers the FAA’s role, the potential for new operational limits on Boeing, the impact and structure of compliance monitorships, and what compliance officers can learn from this high-stakes scenario.Key Highlights·      DOJ and Boeing: The 737 MAX Dilemma·      Corporate Justice: Individuals vs. Corporations·      Balancing Justice and Corporate Interests·      Deferred Prosecution Agreements: Compliance Challenges·      07:33 Financial Penalties vs. Operational Limits·      The Potential of Monitorships·      FAA's Role and Challenges·      Compliance Lessons and Future ConsiderationsResourcesMatt on Radical Compliance Tom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly delve into the recent speech by Michael Hsu, the head of the Office of the Comptroller of the Currency, on the accountability challenges posed by artificial intelligence in the banking sector. The discussion highlights Hsu's emphasis on the lack of a robust accountability framework for AI, illustrating the issue with the Air Canada chatbot incident. The conversation also touches on potential systemic risks AI could pose to the financial sector, the need for explainable AI, and the shared responsibility model used in cloud computing as a potential template for addressing these challenges. The episode underscores the necessity for compliance officers to ensure contracts and IT controls are in place and stresses the importance of developing trust and accountability mechanisms before widespread AI adoption.Key Highlights·      AI Accountability: A Regulator's Perspective·      Case Study: Air Canada's AI Mishap·      Legal and Technological Challenges·      Exploring Solutions and Shared ResponsibilityResourcesMatt on Radical Compliance Tom  InstagramFacebookYouTubeTwitterLinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices