Compliance into the Weeds

By Tom FoxBusiness News Business News Management

Compliance into the Weeds episodes

March 11, 2020OCC Guidance on 3rd Party Risk Management
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 we take a deep dive into recent OCC Guidance on managing 3rd party risk.
Some of the highlights include:
What was the Office of the Comptroller of the Currency, guidance published the on March 5?
Why is 3rd party risk still a chronic issue?
What is the role of due diligence?
What are sustainable business models for 3rd party risk management?
What are 4th party risks?
What is Kelly’s Law of 3rd Party Risk Management?
A short discussion of FINRA’s new bulletin on pandemic risk?
Resources
Matt Kelly blog post, Some Good Guidance on 3rd Party Risk

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23 min
March 04, 2020Cardinal Health FCPA 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. In this episode we take a deep dive into Cardinal Health FCPA enforcement action brought by the SEC.
Some of the highlights include:
What is the background to the matter?
How did a Chinese acquisition cause so much FCPA grief?
What were the types of business relationships involved?
How did the corporate office respond?
What red flags were spotted or missed?
Why didn’t the corporate office take stronger action?
What was the SEC’s response in the fine and penalty phase?
Resources
Matt Kelly blog post, Cardinal Health Pays $8.8 Million on FCPA Issues
Tom Fox blog post, Cardinal Health FCPA Enforcement Action: High Risk Business Relationships

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20 min
February 26, 2020Barr Sentencing Memo and Trump Pardons
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 we take a deep dive into Donald Trump ordering (via Twitter) the AG to reduce the length of sentence requested for Roger Stone and his pardons of 13 convicted white-collar criminals.
Some of the highlights include:
What is the background to the Barr Sentencing Memo?
Can white collar defense lawyers use the DOJ reasoning to decouple of the sentencing guidelines?
What does all this mean for corporate culture?
When will Trump start attacking companies for doing business ethically?
What are the implications for the compliance discipline and CCO?
What tensions does all this create for the corporate compliance and corporate legal functions?
What happens when arbitrary behavior emanates from the top of an organization?
Resources
Matt Kelly blog post, Lessons from Justice Department Meltdown

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26 min
February 12, 2020Hogan Lovells Report on Compliance Budgets
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 we take a deep dive into recent Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020. We conclude with a special tribute to Bernie Ebbers and his role in creating the modern compliance professional. Some of the highlights include:
What do the survey results say about the direction of compliance function spending?
Can companies manage risks in emerging markets when compliance spending is decelerating?
Technology can improve compliance efficiency but it can also improve compliance evasion.
Will CCOs be able to interpret data from ComTech tools?
What are the implications for the compliance discipline and CCO?
Resources
Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020, click here.
Matt Kelly blog post, Compliance Resources Getting Tighter

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23 min
February 05, 2020Wells Fargo Risk Assurance Execs Under Scrutiny
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 we take a deep dive into the Office of Comptroller and Currency’s proposed Cease and Desist Order against former high-ranking Wells Fargo risk assurance executives.
Some of the highlights include:
Are risk assurance executives now under more scrutiny by regulators?
Were the facts of Wells Fargo’s fraudulent accounts scandal so bad to raise a new level of liability?
Should we expect new regulatory guidance?
If the first line of defense performs it function, but the second and third do now; what are the implications?
What are the implications for the compliance discipline and CCO?

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22 min
January 29, 2020The 2020 Edelman Trust Barometer
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 indulges me as we take a deep dive into 2020 Edelman Trust Barometer and its implications for the CCO and corporate compliance function.
Some of the highlights include:
Why is trust down so much in developed countries while going up in under-developed countries?
Why is the trust gap widening between the well-educated and others?
While respondents tend to trust their employers, why is business in general seen as untrustworthy?
What does the growing gap in executive pay portend for employee trust?
What are the implications for the compliance discipline and CCO?
Resources
Download the Edelman Trust Barometer here.
Read Matt’s blog post, Edelman Trust Report Gets Grim

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21 min
January 22, 2020 Lessons from the Astros Sign Stealing Scandal
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 indulges me as we take a deep dive into the Houston Astros sign stealing scandal. We mine the episode for compliance and ethics lessons. It turns out there are quite a few.
Some of the highlights include:
Ø  What was the role amnesty to the players played in both the speed of the MLB Report and its thoroughness?
Ø  Does the MLB sanctions against Luhnow and Hinch send a clear (enough) signal?
Ø  It was a technology innovation which led to the scandal. How does that inform a compliance professional?
Ø  Houston’s culture was broken. How can it be fixed?
Ø  Did the Mets and Red Sox both actually consider keeping Alex Cora and Carlos Beltran? If so why?
Resources
Tom’s five blog posts (to date) in the FCPA Compliance and Ethics Blog.
Part 1-The Scandal
Part 2-Luhnow and Hinch
Part 3-Compliance Lessons
Part 4-Ethics and The Truth of the Game
Part 5-the Whistleblower and Amnesty

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40 min
January 15, 2020Compliance Issues in 2020, Part 2
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. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 2 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.

Some of the highlights include:
The Institutional Shareholder Services lawsuit against the SEC. What will this and other court cases against the Trump Administration’s attempt to gut shareholder protects by the SEC?
Effective sanctions compliance programs. Will there be congruity or discrepancies in the interpretation of what constitutes a best practices compliance program by the DOJ and OFAC.
Compliance convergence. We are moving to do away with anti-corruption compliance, trade sanction and export control compliance, AML compliance to a role which is simply compliance.
Data, data and more data. Regulators now expect data analytics, continuous monitoring and continuous improvement in your compliance program.
The ethical edge. How more effective compliance creates more efficient business process equating to greater profitability.

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27 min
January 08, 2020Compliance Issues in 2020, Part 1
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. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 1 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.
Some of the highlights include:
A legislative fix to the Supreme Court’s Digital Realty Trust decision? Can Congress do anything, including overturning this anti-compliance ruling.
The Fed will take a look at technological service providers? How this will impact compliance.
Climate change disclosures. We use this topic to consider the impact on corporate governance, Boards and mandated disclosures.
Disgorgement at the Supreme Court. Will the SCt allow fraudsters to keep their ill-gotten gains?
Critical audit matters. Will companies move make controls more data based and less subjective?
Check in next week, where Matt and Tom continue the discussion.
Resources
Matt’s blog post 7 Compliance Items to Watch in 2020 in Radical Compliance.

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35 min
December 24, 2019 Continued Missteps and Misadventures in Ethics by Boeing
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 I go into the weed over the ethical failings and missteps made by the now former Boeing CEO Dennis Muilenburg which led to his firing.
Some of the highlights include:
Ø  What are the three steps in cooperating with the government after a failure?
Ø  Why did Boeing fail to reveal negative information it uncovered in its internal investigation?
Ø  What is the role of a CEO around ethics?
Ø  What is the role of the Board of Directors?
Ø  What is the only control for a CEO around ethics?
Ø  What are the lessons learned for a corporate compliance program?
Ø  What does all this mean for compliance professionals going forward?
Resources
Matt’s blog post More Misadventures in Ethics From Boeing in Radical Compliance.

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29 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…