Compliance into the Weeds

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 and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take up the recent CFTC enforcement action involving Bank of America.

In yet another reminder of the importance of ethical practices within the banking industry, Bank of America recently faced civil charges for misconduct, including a junk fees scheme and opening credit cards for customers without their authorization. This follows in the footsteps of similar misconduct from Wells Fargo in the mid-2010s, which resulted in a hefty $185 million fine. To address the issue, Bank of America has agreed to discontinue its flawed incentive program and develop a compliance plan within 90 days. Banks must remain vigilant in their compliance efforts, capture customer consent and documentation, and have data analytics capabilities, or risk similar fines. Furthermore, this penalty emphasizes the need for banks to keep their practices updated with regulations.

  Key Highlights 

·      Facts of enforcement action

·      BOA penalty

·      BOA remediation

·      Comparisons to Wells Fargo

·      Banks behaving badly

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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 sanctions compliance? Look no further than Compliance into the Weeds! 

In this episode, co-hosts Tom Fox and Matt Kelly are joined by Compliance Man himself Tim Khasanov-Batirov. We consider how the Airbus scandal has highlighted the importance of compliance and ethics in corporate conduct in France, and the need for reliable data in ESG reporting, artificial intelligence, and third party risk management. We also discuss the challenges faced by American and European compliance professionals, and the need for Diversity, Equity and Inclusion (DEI) in creating a strong speak up culture. They discussed the EU Whistleblower Directive, which states that anonymous reports should be allowed, and the importance of clean conduct in government agencies. Compliance practitioners have an important role to play in this process, and the EU is leading the world's discussions around ESG reporting.

Key Highlights 

·      ESG Reporting Requirements

·      AI and DEI in Compliance

·      European Compliance Challenges

·      European Compliance vs US

·      AI and Compliance in France

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Tom 

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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 sanctions compliance? Look no further than Compliance into the Weeds! 

In this episode, co-hosts Tom Fox and Matt Kelly dissect the Navex 2023 State of Risk and Compliance Report. Tom and Matt delve into Navex's annual benchmarking report, which surveyed 1,300 compliance professionals. The report revealed that 53% of respondents described their compliance programs as mature. The speakers question whether the board is driving the conversation or if compliance officers are requesting updates due to potential liability. The report's findings on cybersecurity and privacy concerns, survey results on where compliance should reside in a company, and the importance of having a mature anti-bribery anti-corruption compliance program are all discussed. Tune in to hear more about how compliance officers can address pressing concerns such as cybersecurity breaches and attacks. 

Key Highlights 

·      Navex's benchmark report on compliance programs

·      Board-Compliance Officer Relationship & Cybersecurity in Compliance

·      Necessity of Dedicated Compliance Committees

·      Survey Finds Diverse Views on Compliance Placement in Companies

·      The Importance of Anti-Bribery Compliance for Cybersecurity

·      Compliance Officer Reporting to CISO Dynamics

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Matt 

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Tom 

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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 sanctions compliance? Look no further than Compliance into the Weeds!

In this episode, co-hosts Tom Fox and Matt Kelly dissect a disastrous 10k report filed by Ammo Incorporated, exposing the company’s shocking governance and compliance breakdown. The lack of personnel, internal control processes, and proper segregation of duties are just some of the material weaknesses that led to this corporate disaster. The hosts provide insightful lessons on what companies should avoid to maintain internal governance, share tips on approaching remediation, and emphasize the importance of self-awareness among senior management and the board. Tune in to hear how this niche investigative story was uncovered, and how Twitter played a crucial role in the investigation. Don’t miss Compliance into the Weeds – the podcast that will change the way you think about governance and compliance!

 Key Highlights 

·      Material weaknesses in internal governance practices

·      Material weaknesses in operations at Ammo

·      Challenges with Ammo Inc.'s strategic shift and internal controls

·      Remediating Company Failures: Story's Disclosure

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Matt 

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Tom 

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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 sanctions compliance? Look no further than Compliance into the Weeds! 

Tom Fox and Matt Kelly are back with another thought-provoking episode discussing the proposed new Audit Standard 2405 by the PCAOB. This new proposal requires auditors to evaluate legal violations and noncompliance that could have a material impact on financial statements. While some people believe this is a good idea, others question the cost and whether audit firms are trained for this task. The discussions covered a range of topics, including internal control evaluations, expanding audit duties, Wells Fargo case study, the potential for increased audit fees, and reporting noncompliance to law enforcement. The hosts urge listeners to read the proposal and provide feedback as the final standard is expected to be approved by the SEC. This is a must-listen for compliance professionals who want to stay up-to-date and think critically on the latest audit news.

 Key Highlights 

·      Auditing Process for Legal and Compliance Issues

·      New Standards for Auditors Beyond Financial Reporting

·      Expanding PCAOB's Legal Obligations for Auditors

·      Expanding Audit Firm Duties: Impact and Concerns

·      Commenting on Proposed Audit Rule

Notable Quotes:

“This seems like a huge expansion of what auditors have done in the past.”

“Certainly, for example, a large FCPA violation if you're looking at $1,000,000,000 fine, and that would definitely strike me as material.”

“The proposal to expand the duties of audit firms is a dramatic expansion of what they were previously asked to do, and it is unclear whether they are fully equipped to handle this responsibility.”

“Internal auditors and compliance officers may also have concerns.”

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Matt 

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Tom 

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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, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom and Matt as they delve into middle managers' crucial role in fostering a culture of ethics and compliance within organizations. In this episode, the hosts discuss compliance officers' challenges in working with middle managers and share some practical tips on building alliances, teaching soft skills, and developing personal relationships. They also examine the use of incentives and consequence management in promoting compliance and highlight the need for positive incentives for middle managers. Take advantage of this insightful and thought-provoking discussion on enforcing internal controls in a compliance program and learn more about the different ways to ensure compliance in gift travel and entertainment expenses. Tune in now to stay ahead in the world of compliance!

Key Highlights:

 Notable Quotes:

“Compliance officers need to think about because you live and die in the success of your corporate culture, and the middle managers are the custodians of that culture.”

“Compliance officers should think about how do I help middle managers. How do I coach them on how to be good leaders?”

“Nothing is as significant as that personal touch point.”

“If the middle manager either turned a blind eye to the unethical practice or should have known about it but was just so aimless about it and didn't care, should that middle manager suffer consequences along with the frontline employees who committed the offense? And the answer was generally yes.”

 Resources

Matt 

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Tom 

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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, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom Fox and Matt Kelly on “Compliance into the Weeds” as they delve into the recent SEC crackdown on messaging apps and improper employee use. The hosts explore the challenges of regulating messaging app use and provide solutions emphasizing the importance of corporate culture and risk management strategies. Hear from experts like the DOJ representative who spoke at Compliance Week 2023 and a defense contractor who offers tech solutions to monitor messaging apps on employees’ phones. With GDPR and FINRA regulations to consider, the podcast presents a comprehensive plan for compliance officers that focuses on effective controls, processes, and consequences for policy infractions. Don’t miss out on this informative podcast highlighting the importance of cultivating relationships with internal audit teams, IT teams, and other control departments to ensure proper compliance measures.

 Key Highlights: 

 Notable Quotes:

“Assess your risks, put a risk management strategy in place, execute that strategy, train your employees, monitor the effectiveness, and remediate as appropriate.”

“And the tech company CEO said it is in his mind, People the policies, procedures, people and processes a more culture compliance strategy could work, but you would need to convince employees.”

“If they are also violating the policy, that’s bad. And that shows you have a corporate culture problem.”

“If it’s corporate culture, how is this any different than any difficult issue we’ve seen in compliance over the past 15 years?”

Resources

Matt 

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Tom 

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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, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Get ready to dive into the fraud risk management and prevention world with Compliance into the Weeds, hosted by Tom Fox and Matt Kelly. In this episode, they break down the recently released fraud risk framework by COSO and the Association of Certified Fraud Examiners and how it’s necessary for today’s cyber-based fraud and cryptocurrency. They stress the importance of data analytics and internal hotlines to prevent fraud and that all employees need to be trained to detect and prevent fraud in their industry. The hosts also discuss how financial reporting controls may not always detect fraud and how anti-fraud controls are essential. With the rise of new types of fraud like ESG and greenwashing, the hosts recommend the fraud risk report for audit and compliance professionals to stay informed about risks swirling around corporations today. Take advantage of this informative and fascinating podcast. Tune in to Compliance into the Weeds now.

 Key Highlights:

·      Fraud Risk Management: COSO Report 2nd Edition

·      Effective Fraud Prevention Training for Employees

·      Importance of Anti-Fraud Controls in Fighting Fraud

·      COSO Fraud Risk Guidance and the Fraud Pentagon

Notable Quotes:

“But when you think about it, we have a lot of external factors, such as the rise of cryptocurrency, which is riddled with fraud and corruption risk. New methods of cyber-based fraud, which didn’t exist, say, 2016, the 2010s before that. Rise of ransomware in particular, which wasn’t quite a big thing back then that it is all over the place now.”

“Most frauds, you the risk management function, you might never catch them. By looking for them, you’ll have to depend on somebody else coming to you from the enterprise, say, I think this person over here is doing something sketchy.”

“Fraud is having a moment. And fraud risk is on the forefront of many people’s minds from many different areas.”

“We need to do better at finding ways to assess and understand your fraud risk and then implementing new controls as necessary to push that risk down to acceptable levels.”

Resources

Matt 

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Tom 

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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 to stay updated on compliance and ethics? Look no further than Compliance into the Weeds, with co-hosts Tom Fox and Matt Kelly! 

Looking to stay updated on compliance and ethics? Tune in to the Compliance into the Weeds podcast with hosts. In this episode, they tackle the corruption scandal involving ComEd and its parent Exelon, and highlight the progress made in their compliance program reforms. With the release of their second public progress report, compliance and corporate executives can learn from changing ComEd's company culture and supply chain overhaul. The podcast also dives into integrating compliance concerns into HR processes and identifying supervisory groups that may need closer monitoring. Don't miss out on this informative and insightful episode available now!

Key Highlights 

·      Significance of the report

·      Compliance and the Supply Chain

·      Compliance and Exit Interview

·      Using this report going forward

 Notable Quotes:

“I just have to acknowledge that state of Illinois finally convicted someone for corruption.”

“These reports provide not just simply a roadmap of how to change culture, but really a way to think through what may seem like an insurmountable problem.”

“I applaud Exelon for establishing this comprehensive supply chain risk management effort and making supply chain compliance a big part of its supply chain risk program.”

“It is compliance, which is driving overall supply chain risk management and business efficiency, which is inevitably lead will inevitably lead greater profitability if done correctly and that with a variety of other areas and companies having supply chain risk.”

 Resources

Matt 

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Blog Post in Radical Compliance

Check out our prior podcast on ComEd’s 2022 Compliance Report here

Tom 

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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 and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Tom Fox and Matt Kelly dive into the recent enforcement action against British American Tobacco (BAT) for violating North Korean sanctions. After years of evading sanctions and funneling over $630 million, regulators have imposed the maximum penalty. Join the podcast to understand the scheme enacted by BAT and the consequences of their actions. They also discuss the need for clarity around who is responsible for ensuring compliance with OFAC and the Justice Department for the next 5 years. With potential penalties looming, the consequences senior management could face, and the extent of compliance commitments expected of BAT, this is a case you want to take advantage of. Listen to Tom and Matt make sense of this perplexing case and what it means for companies in countries like North Korea. 

Key Highlights:

 ·   Sanctions enforcement on British American Tobacco

·   The North Korean Scheme of British American Tobacco

·   British American Tobacco's Sanctions Compliance Penalty and Requirements

·   Legal implications of BAT's North Korea joint venture

Notable Quotes:

“I almost think we should just name this series, ‘the hits just keep on coming’ as sanctions is the new FCPA.”

“This is a long-running, complicated scheme involving the highest levels of BAT knew this was going on to evade sanctions risks.”

“Short of Activision Blizzard, this case strikes me as 1 of the most egregious that we have seen in any form of trade control, export control, trade sanctions, FCPA, or other major corporate white collar.”

“They talk about how BAT and its subsidiaries knew full well that US sanctions said you can't do business with North Korea; they were upset over how BAT publicly announced it.”

 Resources

Matt 

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Tom 

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