Compliance into the Weeds

By Tom FoxBusiness News Business News Management

Compliance into the Weeds episodes

November 30, 2022Mental Health and Compliance Officers
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. In this episode, we consider the very prescient topic of mental health and compliance officers. There is a mental health crisis in the U.S. workforce today, and that applies to compliance officers as well. Matt recently moderated a webinar, hosted by Ethico, on how mental health issues can affect corporate culture and compliance officers themselves. The panelists included Paul Liebman, head of compliance at Harvard University; and Sarah Ross, a former compliance officer at Novartis who now runs a consulting business on burnout, depression, and related issues; and Nick Gallo, co-CEO at Ethico.
Some of the highlights included:
How the Covid-19 pandemic accelerated the issues of mental health for all workers.
We had some great suggestions from the panelists and webinar participants.
Understanding the difference between mental health and mental illness, is critical.
Consider how your company could weave mental health awareness into training, and especially manager training.
Define boundaries between work and personal life.
Why find yourself a friend in your field can be a critical mental health safety check. If you feel like you have someone to speak to about stress, you’re more likely to understand and confront that stress. True for compliance officers and other employees alike.
There is a strong connection between mental health and a speakup culture generally. If employees feel afraid to speak up about feeling stressed or overworked, would they be equally reluctant to speak up about misconduct.
Resources
Matt Kelly in Radical Compliance

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21 min
November 16, 2022 From $34 Billion to $0 in One Week-FTX and Controls
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. In this episode, we consider the recent collapse of the crypto currency trading platform FTX. We look at it from a variety of angles. Highlights include:
·       Where does FTX rate in terms of catastrophic business failures?
·       What were the internal control failures?
·       How much fraud was involved?
·       FTX is domiciled outside the US. What does that mean for the review process?
·       Will this lead to regulation over crypto?
Resources
Matt Levine in Bloomberg on FTX’s balance sheet
Matt Kelly in Radical Compliance

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24 min
November 09, 2022 300th Anniversary Episode - Policies Policies Policies
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. In this special 300th Anniversary episode, we consider a recent academic paper which suggests that policies play a small role in persuading employees not to engage in bribery and corruption. Highlights include:
·       What did the paper conclude?
·       What is the role of procedures?
·       Tom details the one function of policies.
·       How does an operationalized compliance program work?
·       What is the intersection of policies and internal controls?
Resources
Matt in Radical Compliance

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29 min
November 02, 2022 Thinking about Clawbacks
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. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include:
·       What are clawbacks?
·       What does the SEC rule require?
·       Are clawbacks the mirror of executive incentives?
·       How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements?
·       How far down the corporate chain must a clawback provision impact?
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog

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28 min
October 26, 2022 Lafarge and the Cost of Moral Bankruptcy
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. In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. Highlights include:
·       What are the background facts?
·       What were the bribery and payment schemes?
·       What are the compliance lessons learned?
·       How will the victim status play out?
·       Who will guarantee the compliance of Lafarge with the Plea Agreement.
Resources
Tom in the FCPA Compliance and Ethics Blog

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29 min
October 19, 2022 External Auditors, Fraud Risks and Compliance
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. In this episode, we consider the recent statement by Paul Munter, the SEC’s acting chief accountant, where he urged auditors to do better at assessing fraud risk among their clients. Highlights include:
·       Why did the SEC raise these points in the first place? What are they trying to tell auditors that they’re doing wrong?
·       Are auditors really equipped to be more aggressive in fraud risk assessment and investigation?
·       What should compliance officers be thinking about vis a vis the SEC’s statement?
·       What is the role of compliance in in anti-fraud?
·       How will this impact compliance audits by external auditors and fraud examiners?
Resources
Matt in Radical Compliance

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28 min
October 12, 2022A Hockey Scandal in Canada
Now 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. In this episode, we look at burgeoning scandal from north of the border in Hockey Canada. Highlights include:
What happens when your sport is also your national religion?
How can you affect a change across an entire sports culture.
Who are your stakeholders and are you protecting them?
The Wide World of Sports misconduct.
When (and if and how) will management start to listen?
Resources
Matt in Radical Compliance

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21 min
October 05, 2022The Oracle FCPA Enforcement Action
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. In this episode, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include:
Recidivist behavior in same countries with similar schemes.
Policy, procedure and internal controls failures.
Why no monitor.
Compliance programs lessons learned.
What about the DOJ?
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
Background
The Schemes in Action
Parking in India
The Comeback and DOJ
What it all means

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22 min
September 28, 2022Monaco Doctrine and Memo
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. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include:
Corporate accountability.
Timeliness in turning over evidence of wrongdoing.
Baby Carrots in evaluating corporate history of misconduct.
Additions to Evaluation of Corporate Compliance Programs.
Tweaks to the Yates Memo formulation.
Monitors and Monitorships.
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
Introduction
Self-Disclosure
Corporate Compliance Programs
Monitors
The heat is on
Monaco Memo

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37 min
September 21, 2022 Polite Speech-A Jolt for Compliance
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. In this episode, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include:
·      What are clawbacks and how would they work in practice?
·      Does a lack of corporate clawbacks lead to aggravating factors?
·      How much credit will a company receive by instituting clawbacks?
·      CCO certifications are here to stay.
·      How does the Polite Speech relate to the Monaco Memo.
Resources
Matt in Radical Compliance
Text of Polite Speech

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35 min

About Compliance into the Weeds

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What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in…