By Tom Fox
4.6
99 ratings
The podcast currently has 360 episodes available.
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 explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the Trump Administration’s DOJ nominees, FCPA enforcement going forward, and what it may all mean for compliance professionals.
Tom and Matt explore the potential impacts of these nominations, notably the controversial choice of Matt Gaetz as Attorney General, and how they could shape the direction of anti-corruption enforcement and compliance practices. They also discuss the realistic aspects of other nominees, including Trump’s attorneys Todd Blanche and Emil Bove and former SEC Chairman Jay Clayton, who proposed to lead the Southern District of New York. The conversation touches on potential strategies for compliance officers, such as the increased significance of self-disclosure and the broader ramifications for corporate and foreign policy enforcement under a Trump administration.
Key highlights:
Resources:
Matt in Radical Compliance
Tom
YouTube
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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 explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the recently released FCPA enforcement action involving the Telefónica Venezolana subsidiary.
They explore the bribery scheme used by Telefónica Venezolana to win an auction for U.S. dollars in 2014, resulting in a significant criminal penalty. The episode delves into the complexities of compliance in high-risk jurisdictions, the importance of incorporating anti-corruption due diligence into supply chains, and the implications of the new enforcement landscape under different administrations. Key lessons include the surprising extent of supplier risk, the long tail of FCPA enforcement, and the financial benefits of robust compliance practices.
Key highlights:
Resources:
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
Tom
YouTube
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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 explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this special election day episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into a lighter yet insightful compliance story involving a young boy named Danny Doherty.
At 12 years old, Danny set up a homemade ice cream stand in Massachusetts to raise money for a hockey team for children with developmental disabilities. However, the local health department shut its stand down due to risks associated with homemade dairy products, highlighting the importance of a risk-based approach in compliance activities. Tom and Matt discuss key compliance lessons from this incident, such as the necessity of addressing real risks, the potential for compliance failures despite good intentions, and the importance of effective communication by regulators.
Key highlights:
Resources:
Radical Compliance
Tom
YouTube
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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 recent events at the Washington Post, where the newspaper decided not to endorse a presidential candidate for the first time in years.
This decision, directed by owner Jeff Bezos, has led to significant backlash, including 200,000 lost subscribers and concerns about the paper’s principles. Matt and Tom discuss the implications of this move on leadership, company values, and stakeholder trust, providing insights into the governance structure of newspapers and the potential fallout of abandoning established principles. We also turn to company values and if you are going to violate them, there should be sufficient justification. Finally, what a second Trump Administration might mean for corporate compliance.
Key Highlights:
Resources:
Matt in Radical Compliance
Tom
YouTube
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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 RTX Foreign Corrupt Practices Act enforcement action.
Their discussion unveils complex bribery schemes involving millions paid to Qatari agents and the family of the Emir to secure defense contracts. Despite strict regulatory oversight, Raytheon’s (now RTX) compliance missteps spanned from 2012 into the 2020s, resulting in massive fines. Matt and Tom scrutinize these failures, detailing the SEC and DOJ’s mandates for dual monitorships due to violations of the False Claims Act and FCPA and the Board’s critical role in addressing these issues. Additionally, a comparative look at other significant FCPA cases, including Moog’s penalties for bribery in India, highlights persistent corporate misconduct and the ongoing challenges in achieving effective corporate compliance.
Key Highlights:
Resources
1. Blogs
Matt in Radical Compliance
2. Tom
YouTube
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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 TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties.
In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank’s compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank’s strategy is a clear warning when a business puts profits over compliance.
Key Highlights
· Introduction to the Flat Cost Paradigm
· Details of the Budget Strategy
· Impact on Anti-Money Laundering Efforts
· Financial Growth Amidst Budget Constraints
Resources
1. Blogs
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
2. Tom
YouTube
3. Enforcement Related Material
A. OCC
OCC Press Release
Consent Order
Civil Money Penalty
B. DOJ
TD Bank US Holding Company Information
TD Bank N.A. Information
TD Bank US Holding Company Plea Agreement and Attachments
TD Bank N.A. Plea Agreement and Attachments
Merrick Garland Remarks
Nicole Argentieri Remarks
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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 study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance.
The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success.
Key Highlights:
Resources:
Matt in Radical Compliance
2024 Benchmarking Study: Testing & Monitoring and Data & Systems
Rethink Compliance
Tom
YouTube
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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 2024 update to the Department of Justice's guidelines for corporate compliance programs, focusing on data and data access.
Tom and Matt explore the significance of these updates and whether they stem from companies showing advancements in data analytics or the DOJ recognizing gaps in data access for compliance officers. The discussion highlights the challenges compliance officers face, especially with diverse ERP systems and data silos, and provides insights into how compliance officers can leverage these guidelines to advocate for better data access within their organizations. The episode also breaks down specific questions from the DOJ’s guidelines, offering practical advice on addressing obstacles to data, resources for data access, and data maintenance.
Key Highlights
· The Importance of Data Access in Compliance
· Challenges in Data Access for Compliance Officers
· DOJ's Six Key Questions on Data Access
· Addressing Data Access Impediments
· Tools and Resources for Data Analytics
· Communicating with the Board on Data Analytics
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
Tom
YouTube
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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 speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute.
Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ’s increased scrutiny on companies speak-up cultures and the protection of whistleblowers.
Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs.
Key Highlights
· Key focus on enhancing whistleblower protections.
· Compliance officers must ensure that reporting mechanisms are well-publicized.
· Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training.
· The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines.
· The practical steps for compliance professionals to align their programs with DOJ’s evolving expectations.
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
Tom
YouTube
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 recent Securities and Exchange Commission FCPA enforcement action involving John Deere.
The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit.
A critical issue was John Deere's delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to.
Key Highlights
· Details of the Bribery Scheme
· Internal Control Violations
· Pre and Post-Acquisition Due Diligence Issues
· Remedial Steps and Improvements
· Root Cause Analysis and Lessons Learned
Resources
Matt in Radical Compliance
Tom
YouTube
Learn more about your ad choices. Visit megaphone.fm/adchoices
The podcast currently has 360 episodes available.
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