Compliance into the Weeds

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. This week, Matt and Tom are joined by Karen Woody and Jonathan Marks to consider the SEC’s recent proposed rules for disclosure of cyber breaches. Highlights include:

·      What was in the proposals? The 60-day comment period is running.

·      The 4-day disclosure requirement for material breaches.

·      The corporate governance issues around Board reporting.

·      What is the SEC trying to accomplish?  

·      Should your company have a cyber-risk committee? If so, who should be on it. 

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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. This week, Matt and Tom take on strange comings and goings of Elon Musk and his participation on the Twitter Board of Directors. Highlights include:

·      When and how did Musk become Twitter’s largest shareholder?

·      Why was he asked to come on to the Board?

·      SEC filing requirement issues?

·      What role did the various stakeholder groups, including employees have in Musk turning down the Twitter Board seat?  

·      What are the compliance and governance issues to be learned?

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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. This week, Matt and Tom take a look at the recent ECI report on the Differences Between Small, Medium And Large Enterprises E&C Programs. Highlights include:

·      Where did this ECI report derive its data?

·      Why are middle sized companies in such bad condition regarding compliance program?

·      Why are middle sized companies having the most issues?

·       When is the time for compliance SME at a company?  

·      When should a company institute robust internal controls?

Resources 

Matt in Radical Compliance

ECI Report - Differences Between Small, Medium And Large Enterprises E&C Programs

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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. This week, Matt and Tom take at the recent remarks by DOJ Assistant Attorney General Kenneth Polite on CCO certifications of compliance programs after the conclusion of a DPA. Highlights include:

·      Where did this issue come from?

·      Is its implementation looming?

·      What are the implications for individual CCO liability?

·       What about CEO liability for recidivism?  

·      What are the corporate governance implications?

Resources 

Text of Kenneth Polite speech

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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. This week, Matt and Tom take a look at the proposed SEC climate change risk disclosure regulations released on Monday. Highlights include:

Resources

Matt Kelly in Radical Compliance

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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. This week, Matt and Tom visit with our Ukrainian colleague Tim Khashinov-Batirov. Tim is well-known in the worldwide compliance community as Compliance Man. He is currently a refugee in The Netherlands at the time of this recording. In this episode, Tim talks about his escape from Ukraine, what life has been like as a displaced person in Europe, the current and burgeoning refugee crisis and some things that we in America can do right now to help those still in Ukraine and those who are refugees. Other topics we consider include:

·      How the bonds of brotherhood between Russia, Belarus and Ukraine may have been permanently destroyed?

·      What do ordinary Russians think about the invasion?

·      Armies like companies run on culture. Why and how has the corruption in the Russian Army hollowed out its culture from the inside?

·       The leadership of President Zelensky and his impact on the Ukrainian people.  

·      The negative leadership of Russia President Putin.

Resources for Donations for Ukraine and Ukrainians

UNICEF

Salvation Army

Red Cross

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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. This week, Matt and Tom take look at a recent speech by SEC Commissioner Alison Herron Lee where she considered the role of lawyers as gatekeepers under SOX 307. Some of the issues we consider 

·      Who do lawyers represent?

·      What is the difference between lawyers and gatekeepers?

·      How can or should lawyers represent multiple interests on SOX issues?

·       How does this comport with state bar requirements? 

·      How, if at all, does SOX 307 impact compliance professionals?

·      Was the speech a policy change announcement, trial balloon or something else. 

Resources

Matt in Radical Compliance

SOX 307

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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. This week, Matt and Tom take a somewhat somber view on the Russia invasion of Ukraine. Some of the issues we consider:

Resources

Tom in the FCPA Compliance and Ethics Blog

Matt in Radical Compliance

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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. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider

Resources

Tom with a 3-part series in the FCPA Compliance and Ethics Blog

Matt in Radical Compliance

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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. This week, Matt and Tom return to one of Matt’s favorite topics Elon Musk/Tesla. Some of the issues we consider:

·      What happens when a business is lead by a runaway CEO?

·      Implications of new SEC investigation.

·       State of California investigation into racial discrimination. 

·      Where has the Board been all this time?

·      Will the attitude of the SEC regarding enforcement change? 

Resources

Matt in Radical Compliance

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