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. In this episode Matt Kelly and Tom Fox take a look the recent domestic bribery and corruption enforcement action involving ComEd, a subsidiary of energy giant Exelon Corp. and the largest utility in the state of Illinois, agreeing to pay $200 million to settle federal corruption charges that also involve one of the state’s most powerful politicians.

Some of the highlights include:

 Resources

See Matt’s blog post, ComEd Pays $200 Million on Domestic Bribery on Radical 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 Kelly and Tom Fox take a look the recent enforcement action by New York banking regulators against Deutsche Bank, which resulted in a $150 million penalty for its business dealings with Jeffrey Epstein. The matter is full of corporate miss-steps, compliance failures, corporate governance disasters and presents a cautionary tale for every compliance professional.

 Resources

See Matt’s blog post, Deutsche Bank’s Many Epstein Failures on Radical 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 Kelly and Tom Fox take a look the recently released FCPA Resource Guide, 2nd edition; released jointly last week by the Department of Justice and Securities and Exchange Commission.

Resources

From Tom, check out his five part blog post series on the new FCPA Resource Guide on the FCPA Compliance and Ethics Blog.

For a copy of the FCPA Resource Guide, 2nd edition, click here.

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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 Kelly and Tom Fox take a look the recently announced Novartis FCPA enforcement action. We discuss the background facts, bribery schemes, fines and penalties, data analytics approach and conclude with lessons learned.

Resources

From Matt, Novartis Settles FCPA Case for $345 Million

From Tom

Part 1-Introduction

Part 2-the Bribery Schemes

Part 3-Internal Controls

Part 4-Fines, Penalties and Recidivism

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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 Kelly and Tom Fox take a look this week’s United States Supreme Court decision in Liu v. Securities and Exchange Commission, which upheld the SEC remedy of profit disgorgement. We consider the background facts of the case and how the Court reached its decision. We also consider what the decision might mean for FCPA enforcement and compliance professionals going forward. 

For a copy of the decision in Liu v. SEC, click here.

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In this special emergency weekend episode (our first) Matt Kelly and Tom Fox take a deep dive into the attempt by AG William Barr to fire the US Attorney for the Southern District of New York, late on the evening of June 19. We consider its legality, what it means for both the SDNY, SEC and white-collar law enforcement going forward. 

 Resources

 See Matt Kelly blog post on Radical Compliance, Turmoil for SEC, SDNY Leadership

Barr tries to fire US Attorney for SDNY. (NYT)

Jay Clayton nominated as new Attorney for SDNY. (CoinDesk)

Berman says will not step down. (WaPo)

Barr does not have authority to fire Berman under Court order appointing him. (Law and Crime)

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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 Kelly and Tom Fox take another deep dive into the Wynn Monitor report. Today we consider the issues around third parties; including vendors in the Supply Chain and the rigor of the approval process and role of the corporate compliance function and CCO. We also discuss how customers and especially high rollers are treated.  

Resources

See Matt Kelly blog post, Wynn Part 2: Third-Party Oversight

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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 Kelly and Tom Fox take a look at two examples of ham-fisted leadership; one by Facebook CEO Mark Zuckerberg and the second by NFL Commissioner Roger Goodell. Both also had to respond to employee near revolts over their poor leadership. For Zuckerberg it was his refusal to stop President Trump’s incendiary and race-bait tweeting. For Goodell, it was lack of acknowledge of the racist murder of George Floyd.

Resources

See Matt Kelly blog post, Two Tales of Ham-Fisted Leadership

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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. This past weekend saw some of the largest protests and violence this country has seen in 50+ years in the wake of the killing of George Floyd. In a very somber episode, in this podcast Matt Kelly and Tom Fox try to make some sense of leadership responses to the protests over the Floyd killing and explore if there is a compliance-based approach to remedying the institutional racism which led to his killing.

Resources

A good general summary of anti-racism resources:

https://docs.google.com/document/d/1BRlF2_zhNe86SGgHa6-VlBO-QgirITwCTugSfKie5Fs/preview?pru=AAABcnb5mB8*DxXs7K_umbRHlS1kzEln3g

A website that gives you specific bail funds for your city: The Bail Project, a nonprofit that aims to mitigate incarceration rates through bail reform.

https://bailproject.org

Other places to donate:

• Black Visions Collective, a black, trans, and queer-led social justice organization and legal fund based in Minneapolis-St. Paul.

https://www.blackvisionsmn.org/about

• The Minnesota Freedom Fund, which pays criminal and immigration bail and bond for people who cannot afford it.

https://minnesotafreedomfund.org/bailbondfaq

• The Brooklyn Bail Fund, which helps pay bail for those who cannot afford it.

https://brooklynbailfund.org/donation-form

• The NAACP Legal Defense Fund, which supports racial justice through advocacy, litigation, and education.

https://www.naacpldf.org/about-us/

• Communities United Against Police Brutality, which operates a crisis hotline where people can report abuse; offers legal, medical, and psychological resource referrals; and engages in political action against police brutality.

https://www.cuapb.org/what_we_do

• Northstar Health Collective, a St. Paul–based organization that provides health services and support at protests.

https://northstarhealth.wordpress.com/about-us/

• The ACLU, which provides legal services and support for a broad range of people with civil rights complaints.

https://www.aclu.org/issues/racial-justice

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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 podcast Matt Kelly and Tom Fox take a deep dive into how business leaders can demonstrate values during times of difficulty, specifically when the CEO of Airbnb was required to layoff nearly 25% of the company’s workforce.

Some of the highlights include:

See Matt Kelly blog post Demonstrating Values During Difficulties on Radical Compliance.

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