Compliance into the Weeds

Compliance into the Weeds

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Compliance into the Weeds episodes

  • The WPP Foreign Corrupt Practices Act 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. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP.

    Some of the issues we consider are:

    • Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture?
    • What is the role of compliance in M&A?
    • When does a financial incentive become perverse?
    • Where is the DOJ? Where is the SFO?
    • How did WPP avoid a monitor? 
    • Resources

      Matt in Radical Compliance

      WPP Pays $19M on FCPA: An Analysis

       Tom in the FCPA Compliance and Ethics Blog

      Part 1-Background

      Part 2-Structural Compliance Deficiencies

      Part 3-Bribery Schemes

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      32 min
    • Lax Anti-Vax Policies

      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 a recent survey around employee attitudes towards employer vaccination policies and enforcement of those policies.  

      Some of the issues we consider are:

      ·      What are employee attitudes toward employer vaccination policies?

      ·      Why is there a split between White Collar response v. Blue Collar responses?

      ·      What will be government enforcement? 

      ·      Will there be increased whistleblower reporting?

      ·      What could be the social media impact on corporate reputations?

       Resources

      Matt in Radical Compliance

      Poll: 46% Would Report Lax Vax Policies

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      26 min
    • Listening is a Conversation

      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 why an internal reporting system is not enough. Indeed having a speak up culture is not enough. Your company must have a listen up culture.  

      Some of the issues we consider are:

      ·      What is a speak up culture?

      ·      What is a listen up culture?

      ·      What are some of the benefits of a true listen up culture? 

      ·      How do you training middle managers to be speak up portals?

      ·      Why is having a conversation so powerful?

       Resources

      Matt in Radical Compliance

      Corporate Culture: Speak Up v. Listen Up

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      26 min
    • High Calorie Compliance Lessons from Kraft Foods

      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 the recent SEC enforcement action involving Kraft Foods. While the subject matter of the enforcement action was fraudulent expense recognition, it turns out the real culprit was a corrupt culture. Some of the issues we consider are:


      ·      What were the underlying facts?

      ·      What does tone at the top really mean?

      ·      How does management cost cutting mantra lead to corruption? 

      ·      Why is incentive based comp so deterius?

      ·      What did SEC Commissioner Crenshaw say about this enforcement action?

      Resources

      Matt in Radical Compliance

      Food For Thought From Kraft Foods

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      28 min
    • Delta Airlines Responds to the Delta Variant

      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 the recent move by Delta Airlines to require employees who refuse to be vaccinated to pay a special health care insurance surcharge of $200 to cover the increased health care costs associated with unvaccinated employees who contract Covid-19. 

      Some of the issues we consider are:

      ·      What were the underlying facts?

      ·      How did Delta Airline’s actions follow a risk management protocol?

      ·      How did Delta’s actions demonstrate a commitment to compliance? 

      ·      How about the data?

      ·      How about Document Document Document? 

      Resources

      Matt in Radical Compliance

      Delta’s Smart Approach on Delta


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      21 min
    • Matt Miner Makes 3-Point Pivot into the Walmart CCO Chair

      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 recent announcement by Walmart that former DOJ Deputy Attorney General, Criminal Matthew Miner had joined the company as CCO.  

      Resources

      Matt in Radical Compliance

      Walmart Names ex-DOJ Boss CCO


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      26 min
    • Pearson SEC 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. This week Matt and Tom take a deep dive into the SEC enforcement involving Pearson. Some of the issues we consider are:

      • How can a failure to disclose lead to a SEC violation?
      • What were the disclosure controls and procedures failures?
      • How is patch management a critical part of cybersecurity?
      • What were the misleading statements made by Pearson?
      • What are the lessons learned?
      • What is the role of compliance? 
      • Resources

        Matt in Radical Compliance

        SEC Schools Pearson on Cyber Disclosure Failures

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        25 min
      • Who Controls Corporate Values?

        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 Venn Diagrams to consider the questions of who sets corporate values. Some of the issues we consider are:

        • What happens when management dictates a corp value?
        • What happens when that value is disputed by employees?
        • What happens when the regulators come knocking?
        • How does social media play into all this?
        • How can you assess your risk?
        • What is the role of compliance?
        • Resources

          Matt in Radical Compliance

          Mapping the Pressures on Corporate Values, Priorities

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          25 min
        • What Happens When a CCO Goes off the Deep End?

          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 actions of Activision CCO Frances Townsend who when faced with a claim by the state of California of sexual harassment by the company in the workplace, went off the deep end. Some of the issues we consider are:


          ·      What happens when a CCO attacks internal whistleblowers?

          ·      How is the role of the CCO different from that of the GC??

          ·      What happens when a company starts attacking its own employees? 

          ·      What happens when a CCO closes their door to employees?

          ·      The over/under on Townsend’s continued employment.

           

          Resources

          Matt in Radical Compliance

          More Activison CCO Drama

          Activision CCO Steps Into a Mess


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          24 min
        • First Energy Corruption Settlement

          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 Deferred Prosecution Agreement entered into by First Energy company for its bribery of certain state officials in the state of Ohio, including the former Speaker of the House in Ohio.

          Some of the issues we consider are:

          • What were the underlying facts?
          • What were the bribery schemes involved?
          • How did the tax code facilitate the bribery?
          • What are the compliance program implications?
          • How does this fit into ESG? 
          • Resources

            Matt in Radical Compliance

            First Energy and Domestic Corruption Woes

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            23 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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