Compliance into the Weeds

Compliance into the Weeds

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Compliance into the Weeds episodes

  • Ransomware Attacks and Internal Controls

    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. Today, Matt and Tom take a deep dive into the difference between a privacy breach and a ransomware attack.

    Some of the issues we consider are:

    • Why are privacy breaches different from ransomware attacks?
    • What is an authenticated v. unauthenticated cyber-attack?
    • Why would the SEC get involved?
    • What are the internal controls need to prevent and detect a ransomware attack? How will they be audited?
    • How can a material weakness in internal controls around ransomware lead to a financial restatement?
    • What will the SEC look at from an enforcement angle?
    • Resources

      Matt in Radical Compliance

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      26 min
    • Red Flags and SPACs

      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. Today, Matt and Tom take a deep dive into several issues regarding Special Purpose Acquisition Companies (SPACs).

      Some of the issues we consider are:

      • What did the Klausner and Olhrogge Research Paper show about conflicts of interest?
      • What did Calcbench analysis show about not only the number of SPAC filings but how they are driving the dramatic increase in M&A activity.
      • What are the corporate governance issues involved in with SPACs?
      • What are the internal controls issues involved with SPACs?
      • What has (or will) the Delaware Supreme Court have to say.
      • What have been the pronouncements from the SEC?
      • Resources

        Matt in Radical Compliance, Paper Raises Red Flags on SPACs Governance

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        27 min
      • A Single Source of Truth

        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. Today, Matt and Tom take a the recently filed lawsuit by Shaquala Williams against JPMorgan for alleged retaliation for her internal whistleblowing. Williams was in a compliance function at the bank and claimed she was terminated for raising the issues that JPMorgan was not living up to its reporting requirements under a DPA.Some of the issues we consider are:

        • Facts of the claim?
        • Made in the context of an ongoing DPA.
        • The lack of lack of documented policies and procedures.
        • Siloed nature of compliance functions.
        • Inconsistency in risk assessments.
        • Why is a single source of truth so critical?
        • Resources

          Matt in Radical Compliance, That Lawsuit Against JP Morgan

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          26 min
        • Retreat on DoD Cybersecurity for Contractors

          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. Today, Matt and Tom take a look at the Department of Defense retreat on its cybersecurity initiative for contractors, from the original CMMC to the new standard of CMMC 2.0.

          Some of the issues we consider are:

          ·      What is CMMC and what morphed into CMMC 2.0?

          ·      Who led the charge to make these changes?

          ·      Do these changes help or hurt federal government overall cybersecurity? 

          ·      Will self-assessments work?

          ·      New FCA claims coming?

          ·      What about compliance?

          Resources

          Matt in Radical Compliance, Pentagon Sounds Retreat on CMMC Compliance

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          22 min
        • More on DAG Monaco Speech-DPAs and NPAs

           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. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms.

          Some of the issues we consider are:

          ·      Are DPAs and NPAs simply the cost of doing business?

          ·      Is the Wells Fargo growth cap a valid model?

          ·      What about greater DOJ or Monitor oversight? 

          ·      Longer terms for DPAs?

          ·      New enforcement tools coming?

          ·      New review of DPAs and NPAs.

          Resources

          Matt in Radical Compliance

          So What Happens Next with DPAs

          Tom in the FCPA Compliance and Ethics Blog

          Monaco Speech - Individual Accountability

          Monaco Speech - Monitors

          Text of DAG Monaco Speech

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          24 min
        • DAG Announces Changes in Enforcement Priorities

          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. Today, Matt and Tom have a rare emergency podcast on DAG Lisa Monaco’s speech to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Some of the issues we consider are:

          • Return to the Yates Memo.
          • Disavowal of the Benczkowski Memo.
          • Change in the FCPA Corporate Enforcement Policy?
          • Whither recidivists?
          • New enforcement tools coming?
          • New review of DPAs and NPAs?
          • Resources

            Matt in Radical Compliance, Justice Dept. Unveils Big Compliance Shifts

            Text of DAG Monaco Speec

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            28 min
          • Credit Suisse and Holistic Risk Management

            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 deeper dive into the recent Credit Suisse enforcement action. Some of the issues we consider are:

            • Is a broader view of risk needed?
            • If so, who would perform that review?
            • Too many silos?
            • Public companies v. investment banks?
            • What is under escalated risk?
            • What is conduct risk?
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              25 min
            • Compliance and AI

              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 deep dive into the issue of compliance and artificial intelligence. Some of the issues we consider are:

              • What are the AI risks for compliance?
              • What guidance does the COSO Framework provide?
              • What are some of the top areas of AI failure?
              • Are we governing AI in the right manner?
              • What about the audit of AI tools?
              • Compliance, governance, ethics and AI.
              •  Resources

                Matt in Radical Compliance

                Thoughts on AI From the Audit Perspective

                Grappling With Artificial Intelligence

                 Tom in the FCPA Compliance and Ethics Blog

                Compliance Communications: Using an AI Marketing Strategy – Part 1

                Compliance Communications: Using an AI Marketing Strategy – Part 2

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                31 min
              • Expansive SEC Enforcement in the Wind

                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 deep dive into a recent speech by SEC Director of Enforcement Gurbir Grewal and the likely increase in a more expansive use of SEC enforcement.

                Some of the issues we consider are:

                • What is the purpose of SEC penalties; to penalize or to deter others?
                • How did SEC Commissioner Crenshaw presage this talk?
                • What about a potential change in DOJ penalties? Its approach and focus?
                • Are monitorships back on the table?
                • What about the CFPB? Will Directors and Officers be held accountable or just the low level minions?
                •  Resources

                  Matt in Radical Compliance

                  More on SEC Penalties Policy Shift

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                  30 min
                • Ozy Media and Culture Failure Bingo

                  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 deep dive into collapse (and perhaps rebirth) of Ozy Media and have our first round of culture failure bingo. 

                  Some of the issues we consider are:

                  • What is an Ozy and why does its collapse matter to compliance?
                  • Who is Ozzie Osbourne and what does he have to do with Ozy?
                  • What is culture failure bingo and why is it on Compliance into the Weeds?
                  • Who were the bingo winning companies this week?
                  • Why all this matter to compliance?
                  • Resources

                    Matt in Radical Compliance 

                    Tom in the FCPA Compliance and Ethics Blog

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                    31 min

                  About Compliance into the Weeds

                  From the publisher's feed

                  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…

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