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. Today we take on a much more somber topic and set of facts in this, our 201st episode. We have our first guest, Diane St. Ives, a retired US Army officer now practicing law in Houston. Diane is also a Director of the State Bar of Texas.

 Matt, Tom and Diane consider the recent US Special Commission Report on leadership and culture failures in the areas of sexual harassment and assault which have occurred at Ft. Hood. These issues were brought to a head with the sexual assault and brutal murder of Specialist Vanessa Guillén, who disappeared on April 22. She was murdered by a fellow soldier, who killed himself in June when he escaped Army investigators taking him into custody.

Some of the issues we consider are:

Resources

For more information see Matt’s blog post in Radical Compliance:

Leadership Failures at Ft. Hood

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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. In this, our 200th episode Matt and Tom go into the weeds to look at the new anti-money launder whistleblower law (AMLA) which is part for the updated Bank Secrecy Act legislation, included in the National Defense Authorization Act authorization of 2012 (get all that). It significantly expands whistleblower protections for those who come forward with AML or other similar allegations. Some of the issues we consider are:

·      Why has this been created for the Department of the Treasury?

·      Who will administer the whistleblower program?

·      What lessons has Congress learned about protecting whistleblowers?

·      Can a CCO be a whistleblower under this new law? How about a GC? 

Resources

For more information see Mengqi Sun’s article in the WSJ Risk & Compliance:

Defense Bill Proposes Anti-Money-Laundering Whistleblower Program 

For an excellent breakdown of the legislation, see the Zuckerman Law Firm’s Whistleblower Protection Law and SEC Whistleblower Awards Blog: 

Anti-Money Laundering Act Establishes Whistleblower Reward Program and Protects Whistleblowers from Retaliation

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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. In this episode Matt and Tom go into the weeds to look at the actions of Denver Mayor, Michael Hancock. Just before Thanksgiving he told folks to stay at home to avoid Covid-19 transmission and then promptly traveled to Mississippi for the Thanksgiving holidays. Some of the issues we consider are: 

Resources

For more information see Matt’s blog post:

More Misadventures in Leadership 

For more information on the Fraud Triangle see Jonathan Marks’ blog post:

Fraud Pentagon

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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. In this episode Matt and Tom go into the weeds to look at recent remarks by SEC Chairman Jay Clayton and Bill Hinman, director of the Division of Corporation Finance, on issues around insider trading compliance programs. Some of the issues we consider are: 

Resources

For more information see Matt’s blog posts:

SEC Warning on Insider Trading Sales

Apple Exec Indicted on Bribery Charge

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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. In this episode Matt and Tom go into the weeds to look at the SEC Chairmanship of Jay Clayton who announced he was stepping down at the end of the year. Some of the issues we consider are:

·      Tom call it a mixed bag and Matt had mixed views?

·      His first 12 to 18 had a series of crisis including a cyber breach at the SEC itself, the PCAOB scandal with KPMG and Crypto-currency issues.

·      Matt felt Clayton did a good job of listening.

·      He worked to open non-capital markets for investment.

·      In the SEC enforcement action, he basically said Elon Musk was too important to Tesla to punish.

·      His abortive move to head the SDNY was reputational disaster.

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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. In this episode Matt and Tom go into the weeds to look at compliance issues relevant to the next administration. Some of the issues we consider are: 

 Resources

See Matt’s blog posts on Radical Compliance- The Biden Administration and 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. In this episode Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Some of the issues we consider are: 

Resources

See Matt’s blog posts on Radical Compliance- Compliance and Career Turbulence

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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. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the US banking and finance entity Goldman Sachs. Some of the issues we consider are: 

Resources

See Matt’s blog posts on Radical Compliance- Goldman Sachs, FCPA and Internal Controls

See Tom’s exploration on the FCPA Compliance and Ethics Blog

Part 1-Introduction

Part 2-Control Failures

Part 3-Fines and Penalties

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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. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are: 

 Resources

See Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCA

See Tom’s exploration the FCPA Compliance and Ethics Blog

Part 1-Introduction

Part 2-The Bribery Schemes

Part 3-The SEC Order

Part 4-The Plea Agreement

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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. In this episode Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management processes. Some of the issues we consider are:

·      Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance.

·      How the OCC Order is an audit road map.

·      What does that mean for compliance on the Board?

·      Did the OCC push out Michael Corbat?

·      Focus on the ERM Blueprint.  

Resources

See Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program

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