Compliance into the Weeds

Compliance into the Weeds

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Compliance into the Weeds episodes

  • SAP Trade Sanctions 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 SAP trade sanction enforcement action. Some of the issues we consider are:

    • What were the underlying facts?
    • How did SAP allow products to get to Iran for so long?
    • How did SAP achieve a NPA even with aggrieved factors?
    • How was the financial penalty calculated?
    • What were the remedial steps SAP engaged in?
    • Why does this enforcement action point towards the need for a more holistic approach to risk?
    •  Resources

      Matt’s blog post on Radical Compliance:

       SAP Nailed on Sanctions Violations

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      24 min
    • Compliance Lessons from the Cuban Missile Crisis

      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 different area; their joint love of history. Matt is reading Nuclear Folly, a new chronicle of the Cuban Missile Crisis by Ukrainian history professor Serhii Plokhy. We use this as a starting point to explore how both the Soviets and Americans used different types of internal debate and information to eventually steer clear of nuclear war. 

      Some of the issues we consider are:

      • What was the Soviet model for information gathering, analysis and debate, both before and during the Missile Crisis?
      • How was the American model of Ex-Comm so different?
      • How do these models inform a speak up culture?
      • How and more importantly why are leadership, corporate culture, speaking up, ethical values all connected.?
      • What does this mean for compliance officers?
      •  Resources

        Matt’s blog post on Radical Compliance:

        Culture and the Cuban Missile Crisis

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        25 min
      • What is risk?

        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 different types of risk including cybersecurity and anti-corruption to lead a broader discuss about the nature of risk, risk management and the future of compliance. Some of the issues we consider are:

        • What is risk?
        • What are the roles of the CISO and CCO for risk management?
        • Who owns risk?
        • What does a BOD want to see around risk management?
        • What does this mean for compliance officers?
        •  Resources

          Matt’s blog post on Radical Compliance:

          The Cracks in Third Party Risk Management

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          21 min
        • Cybersecurity, ERP and 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. This week Matt and Tom take a deep dive into the type of cybersecurity risk where ERP software is compromised due to a bug or other vulnerability. 

          Some of the issues we consider are:

          ·      What are two types of cybersecurity risk?

          ·      How does this second type of risk impact ERP systems?

          ·      What are the compliance implications? Internal Audit?  Crop Governance? 

          ·      What steps can a CISO take?

          ·      What does this mean for compliance officers?

          Resources

          Matt’s blog post on Radical Compliance: 

          More on Cybersecurity, Compliance Risk


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          27 min
        • SPACs and 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. This week Matt and Tom take a deep dive into the recent spate of SPACs which have formed and are gobbling up companies through acquisition. What does it mean from the internal control, risk management and compliance perspective?

           Some of the issues we consider are:

          • What are SPACs?
          • Do SPACs render controls ineffective?
          • What are the requirements under SOX 404b for SPACs?
          • Do SPACs create an inherent conflict of interest between management and shareholders?
          • What does this mean for compliance officers? 
          • Resources

            Matt’s blog post on Radical Compliance: 

            SPACs Draw Internal Control, Governance Concerns

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            24 min
          • Boaty McBoat, Risk and 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. This week Matt and Tom take a deep dive into the recent grounding of the Ever Given in the Suez Canal, which has now been floated free. What does it mean from the risk management and compliance perspective? Some of the issues we consider are:

            • What were the controls in place to stop this failure?
            • What changed which rendered these controls ineffective and even obsolete?
            • What is your risk program around supply chain disruption?
            • Was this a Black Swan event?
            • What does this mean for compliance officers? 
            • Resources

              Matt’s blog post on Radical Compliance: 

              Less Ever Given on Risk and Control

              The bank effect and the big boat blocking the Suez, Brendan Greely in the FT

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              24 min
            • CEOs Perception of Risk, Impact on 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. This week Matt and Tom take a deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management.

              Some of the issues we consider are:

              • What are the top risks CEOs are worried about in 2021?
              • How has that list changed since 2020?
              • What is the digital transformation of business process and risk management?
              • How will compliance response to these new risks?
              • What does this mean for compliance officers? 
              • Resources

                Matt’s blog post on Radical Compliance: 

                Thoughts from CEOs

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                24 min
              • A Punch in the Face to SEC Enforcement?

                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 Commissioner Caroline Crenshaw on a new philosophy in SEC financial penalty enforcement.  

                Some of the issues we consider are:

                • Who is SEC Commissioner Caroline Crenshaw?
                • What was the 2006 policy regarding enforcement priorities?
                • What changes did Commissioner Crenshaw propose?
                • What about the timing of the remarks?
                • Is this a response to the Supreme Court decision in Lui?
                • What does this mean for compliance officers?
                • Resources

                  Matt’s blog post on Radical Compliance:

                  SEC Enforcement Speech, Umm Wow 

                  2006 SEC Enforcement Policy Statement

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                  24 min
                • The ECI 2021 Global Business Ethics Survey

                  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 findings, conclusions and recommendations in the ECI 2021 GBES.  

                  Some of the issues we consider are:

                  • What were the key findings of the GBES?
                  • What pressure are employees under?
                  • What were the findings on observed misconduct and the reported misconduct?
                  • Troubling findings on retaliation.
                  • What has been the impact of Covid-19 on compliance and ethics?
                  • What were the conclusions and recommendations? 
                  • Resources

                    Matt’s blog post on Radical Compliance:

                    Report: Ethics Pressures Mounting on Employees

                    ECI

                    2021 Global Business Ethics Survey

                    Next week, Tom will have a 5-part podcast series on the FCPA Compliance Report, featuring ECI President Pat Harned discussing the 2021 GBES.

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                    29 min
                  • The SEC and Climate Disclosures

                    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 the SEC that it would start paying more attention to companies’ climate change disclosures.  

                    Some of the issues we consider are:

                    • What did acting Chairman Allison Herren Lee announce?
                    • A review of the 2010 Climate Guidance
                    • What changes might be in the offing?
                    • What will the SEC process be going forward?
                    • What frameworks might the SEC use as a guide?
                    • What does this mean for the compliance function?
                    • What are the compliance lessons? 
                    • Resources

                      Matt’s blog post on Radical Compliance:

                      SEC Fires Warning Shot on Climate Disclosure

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                      20 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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