Compliance into the Weeds

By Tom FoxBusiness News Business News Management

Compliance into the Weeds episodes

February 24, 2021 Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer
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 one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.
Some of the issues we consider are:
·      How did this Fubar occur?
·      What was the role of complexity?
·      Why did the employees make this mistake?
·      What about training?
·      Where were internal controls?
·      What is the ‘value for discharge’ defense?
·      Does this all just come down to finders keepers?
·      What are the compliance lessons?
Resources
Tom’s blog posts on the FCPA Compliance and Ethics Blog:
Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The Facts
Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned
The Citibank decision

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36 min
February 17, 2021Employee Trust 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. Last week we considered the SEC regulations requiring companies to detail human capital issues in their annual reports and what it meant for compliance. This led to a week-long dialogue between Matt and myself about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program.

Some of the issues we consider are:
Trust is down.
The now former UK KPMG Chairman who told employees to ‘quit whining’ about the Coronavirus health crisis issue.
Employees are under more pressure to deliver results. What does this do to trust?
Employee to employee trust issues in WFH.
Trust issues around RTW, both employee to employee and management response to employee health and safety issues at the workplace.
Benjamin Moore getting rid of legal department and then restricting employee access to legal assistance.
Greater fear toward retaliation stopping whistleblowers from coming forward.
Resources
Matt’s blog post in Radical Compliance:
Corporate Culture and Human Capital Disclosures
Tom’s blog posts on the FCPA Compliance and Ethics Blog:
A Macro Approach for Human Capital Compliance
Hal Holbrook, Mark Twain and Employee Trust
How to Destroy Employee Trust
Leadership Lessons from Abraham Lincoln

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30 min
February 10, 2021Human Capital Disclosures 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. Today we consider the SEC regulations requiring companies to detail human capital issues in their annual reports. What have some of the initial disclosures revealed? What does it mean for compliance?
Some of the issues we consider are:
Why is this issue so important?
What are the SEC reporting rules?
How did companies report their human capital issues?
What does all this mean for corporate culture?
Resources
Matt’s blog post in Radical Compliance:
Corporate Culture and Human Capital Disclosures

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27 min
February 03, 2021 GameStop 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. Today we consider the GameStop matter through the lens of the compliance profession.
Some of the issues we consider are:
·      What is the background?
·      What are the compliance implications of this matter?
·      Is this a black swan event or just ‘business as usual?
·      Short sellers in the bulls-eye?
·      The role of the regulators?
·      Who are Robinhood’s stakeholders?
·      What is the more relevant precedent; Long Term Capital or the Panic of 1907?
·      What is the role (or responsibility) of social media?
Resources
Check out Tom’s 5-part blog post series on GameStop and Compliance:
GameStop and Compliance-Introduction
GameStop and Compliance-The Shorts
GameStop and Compliance-The Squeeze and Social Media
GameStop and Compliance-The Regulatory Response
GameStop and Compliance-Lessons for the Compliance Professional

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30 min
January 27, 2021WFH, RTW or Something Else
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 we consider what will be the implications of our working environments post-pandemic. Will we be permanently working from home, returning to the office, a mix of both or something else?
Some of the issues we consider are:
What are the compliance implications of a distributed workforce?
How to maintain culture?
Is WFH communications too much like social media?
What about cyber-bullying from co-workers?
Resources
Matt’s blog post in Radical Compliance: Thoughts on Return to Work

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26 min
January 20, 2021 FinCEN Enforcement Action involving Capital One
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 we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective.
Resources:
See Matt's blog post Capital One Whacked on AML Failures
See Tom's blog post the Capital One FinCEN Enforcement

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29 min
January 13, 2021The Deutsche Bank FCPA 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. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.
Some of the issues we consider are:
The Bank’s compliance program was a paper program only.
Where was compliance?
What Red Flags were missed?
Internal Audit did its job but was ignored.
Actual Knowledge of corruption?
What about the DFS?
Resources
Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:
Part 1-Introduction
Part 2- The Bribery Schemes
Part 3- Overlooked Red Flags and Internal Control Failures
Part 4-Recivist Penalty
Part 5-Final Thoughts
Matt’s blog post in Radical Compliance:
Deutsche Bank Control Failures Cost $130 million

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28 min
January 06, 20215 Issues for Compliance Professionals in 2021
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 we consider five issues that compliance practitioners need to watch in 2021. We also talk about the second five which did not make the Top 5 but you still need to watch.
Some of the issues we consider are:
What will be the implications of the Covid-19 vaccine and RTW?
The Anti-Money Laundering Law of 2020.
The first Biden Administration announcement.
Climate Change Disclosures.
The SolarWind Cybersecurity Disaster.
A special bonus from Matt.
Resources
For more information see Matt’s blog post in Radical Compliance:
Five Compliance Events to Watch in 2021

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34 min
December 30, 2020Who Should Oversee and Manage the Hotline
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 we consider the question of who in an organization should oversee a hotline. Once that decision is made, who should manage the hotline.
Some of the issues we consider are:
Why the Audit Committee on the Board should oversee the hotline.
It should be written into the Audit Committee’s Charter.
The hotline manager must have the independence to investigate any issues raised and they must have the competence to do so.
Why the Compliance Function should oversee management of the hotline.
Resources
For more information see Matt’s blog post in Radical Compliance:
Who Should Run the Hotline?

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23 min
December 23, 2020Algorithm Failures in Ethics and Equity at Stanford
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 we consider how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations. Stanford used a faulty algorithm which mandated that only seven of the Health Systems 1300 medical residents would receive the vaccine. As you might guess these front-line health workers were up in arms over Stanford’s incompetence on this issue.
Some of the issues we consider are:
The plan had been for the algorithm to assign vaccination slots for the first 5,000 employees, who would begin receiving the Covid vaccine on Dec. 18.
What were the parameters of the algorithm?
Why was there so little ethics in the process?
Why was there so little equity in the result?
What are the implications for the compliance professional of the use of the algorithm to make such a critical decision?
What does the EEOC decision allowing companies to mandate vaccines for employees mean for compliance?
Resources
For more information see Matt’s blog post in Radical Compliance:
Lessons on Algorithms, Ethics and Equity

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23 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…