Compliance into the Weeds

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Southern Glazer NPA.

The Southern Glazer Wine and Spirits’ non-prosecution agreement is a rare example where prosecutors credited compliance program remediation, rather than self-disclosure or extensive cooperation, as central to a favorable outcome. Southern Glazer, the largest US liquor distributor, faced a major California kickback and bribery scheme involving five former employees, fabricated records, sham agreements, and luxury benefits to retailers and others, along with alleged tax impacts. The company resolved the matter with a $12.5 million payment and a two-year NPA requiring the CEO and CCO to certify program effectiveness. Tom and Matt review how the NPA affirms DOJ’s Evaluation of Corporate Compliance Programs as still relevant and detail remediation steps: major headcount and budget increases, upgraded compliance leadership, audits of marketing spend, enhanced training, strengthened third-party controls and AP payment blocks, outside reviews, and tone-at-the-top messaging.

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Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.

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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a GAO audit of the Department of Homeland Security’s whistleblower retaliation program.

They use it as a case study for corporate compliance officers. DHS employees can report internally via the Office of Inspector General hotline or externally to the Office of Special Counsel. However, the GAO review focused on DHS’s internal process, where the OIG’s Whistleblower Protection Division (eight investigators) investigates retaliation and, if substantiated, sends cases to the Office of the Secretary and ultimately the DHS Secretary for corrective action. Although targets are six months for investigation and 30 days for secretarial action, GAO found investigations averaged 3.2 years (some up to six) amid rising complaint volumes, turnover, and evidence-gathering challenges. Meanwhile, none of the 11 substantiated cases were decided within 30 days because of missing written procedures and no designated accountable official—showing how delayed resolution erodes reporting culture and “institutional justice.”

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Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.

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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them fully and uncover hard-hitting compliance insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the growing compliance and cybersecurity challenges posed by agentic AI.

They focus on New York Department of Financial Services (DFS) guidance on cybersecurity risk assessments and a European survey Kelly cites. They argue DFS’s rule, requiring annual or as-needed reassessments after significant technology and threat changes and maintaining an accurate IT asset inventory, implicitly compels organizations to identify and track AI agents, even though agents are not mentioned. Kelly cites a Veeam Software survey of 1,000+ European executives reporting limited visibility into employee-created autonomous AI workflows and AI interactions with sensitive data, complicating EU AI Act requirements for human accountability. The conversation compares potential governance models to Sarbanes-Oxley sub-certifications and enterprise software management, questions whether CISOs can certify compliance amid decentralized agent creation, and notes potential enforcement avenues and the risks of industry self-regulation.

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Matt in Radical Compliance (2 posts)

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcasts, and a Top 12 Risk Management Podcasts. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.

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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the NBA’s sanctions against the Los Angeles Clippers for a salary-cap circumvention scheme tied to Kawhi Leonard.

In this delicious set of compliance imbroglios, senior management, including owner Steve Ballmer, allegedly arranged sham endorsement deals with four business partners and offsetting Clippers business to funnel about $18 million in extra compensation, plus improperly pay Leonard’s personal expenses. Tom and Matt review the Wachtell Lipton 36-page investigation detailing sparse contracts, unusual counterparties, rapid deal timing, and incriminating emails (including from Gillian Zucker), as well as recidivism after a similar 2019 violation. Penalties include a $30 million team fine, Leonard’s $700K fine, loss of first-round picks for five years, and suspensions for Ballmer, Zucker, and the basketball operations executive. Meanwhile, Ballmer denies wrongdoing and says the Clippers will file an appeal. They highlight contract-management and third-party due diligence lessons from FCPA-style guidance, the need to analyze patterns across multiple agreements, and the value of strong compliance roles in pro sports.

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Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and w3 Awards, all for podcast excellence.

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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. 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 discuss the recent BAE export control enforcement action.

Matt views the BAE export control enforcement action as a strong example of how ITAR compliance failures often stem from routine breakdowns in day-to-day operations rather than dramatic smuggling schemes. He notes that BAE’s U.S. subsidiary sent technical information and services overseas without proper licenses, including to China and even some allied countries, showing that export controls apply to both data and services, not just physical weapons. Kelly argues that the case reveals common compliance weaknesses such as poor training, unclear procedures, weak system warnings, and employee turnover that can leave staff unsure of the rules. His broader point is that companies in export-controlled industries must maintain current licenses and build strong, monitored compliance programs because governments will continue using export controls as an important geopolitical tool.

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Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.

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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. 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 discuss Kelly’s collaboration with Ethena to run short, paid online AI classes for compliance professionals.

Since May, there has been an excellent AI training for compliance professionals, covering vibe coding, content/video generation, and data analytics with hands-on exercises using dummy or public data. Kelly says his biggest takeaway has been how much AI education is still needed and that many compliance teams are only scratching the surface, despite fears that “everyone else” is further along. They review common tools but emphasize that success depends more on the inputs and outputs, data readiness, clear use cases, and acting on results than on which model is chosen. They also address governance, security, privacy, maintenance, technical debt, costs and token budgets, and the need to involve compliance, which often leads to AI governance. The episode ends with reflections on Dolly Parton’s leadership and a story about her retaining rights to the hit song “I Will Always Love You.”

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Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence. 

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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them in greater depth and uncover hard-hitting insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ’s “McDonald Memo.”

This DOJ Memo outlines a new Trump administration fraud division that broadly claims jurisdiction over “all types of fraud,” potentially reshaping DOJ enforcement and creating uncertainty about overlapping authority with existing divisions (e.g., antitrust). They review five priority areas: a. public trust/financial integrity fraud (procurement, bid rigging, grants, social welfare), b. healthcare fraud, c. internal revenue fraud, d. global trade and commerce fraud (tariffs/customs), and e. an undefined “corporate misconduct” category. From a compliance perspective, they urge companies to reassess risk areas (healthcare, importers, and government contractors), strengthen third-party oversight and documentation, and “pressure test” compliance programs with transparency and recordkeeping. They also warn that politicized enforcement and unclear guidance—such as on cartel-related liability—complicate compliance strategy and may tempt leaders to treat settlements as a cost of doing business.

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Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence. 

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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. 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 celebrate the return of Ted Lasso for Season 4.

Tom and Matt begin with why Ted Lasso resonates with compliance officers as a study of workplace dynamics, leadership, and building a culture of trust. They highlight how Ted focuses on coaching people and shaping club-wide culture through “thousands of imperceptible moments,” culminating in “total football,” where shared expectations and mutual support enable improvisation and performance. They connect this to compliance goals of embedding ethics so employees can handle new situations on the fly and to Jim Collins’ “level five” leadership and humility, illustrated by Ted renaming Trent Crimm’s book from “The Ted Lasso Way” to “The Richmond Way.” They also link the show to the military OODA loop (observe, orient, decide, act) as a model for empowered decision-making within clear objectives and boundaries and preview Season 4’s shift to Ted coaching a women’s team.

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Resources:

Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence. 

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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. 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 discuss a newly issued FinCEN consent order sanctioning UBS Financial Services, the U.S. broker-dealer subsidiary of UBS.

It is a $125 million penalty, the largest FinCEN fine against a broker-dealer, for extensive anti-money laundering failures. They highlight weak transaction monitoring and suspicious activity reporting (SAR) processes, poor customer due diligence, inadequate wire-transfer data collection, and data governance gaps that led to under-reporting and hindered FinCEN’s ability to build a complete money-laundering picture. The order notes UBS failed to monitor more than 50,000 foreign-currency wires totaling over $10 billion and did not disclose ongoing deficiencies discovered after a 2018 $14 million FinCEN action requiring fixes by 2021, with problems traceable back to 2004 and not addressed until 2023. They frame the matter as a tone-at-the-top and resourcing failure, compare it to other enforcement actions (including a recent SEC fine against Merrill Lynch), and suggest a future deeper dive after reviewing the full order.

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⁠USB Consent Order⁠

 Tom  

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence. 

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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 it more fully. 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 discuss the recent FCPA resolution with the Scoular Company. Both Tom and Matt have blogged on this matter, so check out the Resources link below for additional discussions.

The recent FCPA enforcement action against Scoular Company involved a $10.2 million payment and a three-year deferred prosecution agreement over bribes by third-party customs brokers to Mexican border officials to expedite cross-border shipments. DOJ emphasized alleged cartel connections, including a strong statement from the U.S. Attorney for the Western District of Texas, which raised questions about expanded local U.S. attorney involvement and how cartel or potential FTO designations could heighten trade and compliance risks. The company received no voluntary self-disclosure credit but got a 25% discount, with remediation cited (including dropping brokers and strengthening tone at the top). They highlight off-channel WhatsApp use, the lack of released key documents (DPA, statement of facts, criminal information), and practical compliance takeaways on third-party oversight, data analytics, and risk assessments.

Resources:

Matt in Radical Compliance

Tom in FCPA Compliance and Ethics Blog

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.

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