Compliance into the Weeds

Everything Old is New Again - The John Deere FCPA Enforcement Action


Listen Later

The award winning, 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. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the recent Securities and Exchange Commission FCPA  enforcement action involving John Deere. 


The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit. 


A critical issue was John Deere's delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to.


Key Highlights


·      Details of the Bribery Scheme

·      Internal Control Violations

·      Pre and Post-Acquisition Due Diligence Issues

·      Remedial Steps and Improvements

·      Root Cause Analysis and Lessons Learned


Resources

Matt in Radical Compliance


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

...more
View all episodesView all episodes
Download on the App Store

Compliance into the WeedsBy Tom Fox

  • 4.3
  • 4.3
  • 4.3
  • 4.3
  • 4.3

4.3

11 ratings


More shows like Compliance into the Weeds

View all
The Lawfare Podcast by The Lawfare Institute

The Lawfare Podcast

6,287 Listeners

FCPA Compliance Report by Thomas Fox

FCPA Compliance Report

19 Listeners

The New Yorker Radio Hour by WNYC Studios and The New Yorker

The New Yorker Radio Hour

6,686 Listeners

Stay Tuned with Preet by Preet Bharara

Stay Tuned with Preet

32,400 Listeners

Corruption Crime & Compliance by Michael Volkov

Corruption Crime & Compliance

43 Listeners

GZERO World with Ian Bremmer by GZERO Media

GZERO World with Ian Bremmer

739 Listeners

Innovation in Compliance with Tom Fox by Thomas Fox

Innovation in Compliance with Tom Fox

16 Listeners

Great Women in Compliance by Lisa Fine and Hemma Lomax

Great Women in Compliance

55 Listeners

The Bulwark Podcast by The Bulwark

The Bulwark Podcast

11,592 Listeners

Everything Compliance by Thomas Fox

Everything Compliance

1 Listeners

Daily Compliance News by Tom Fox

Daily Compliance News

7 Listeners

The Journal. by The Wall Street Journal & Gimlet

The Journal.

5,916 Listeners

The Ezra Klein Show by New York Times Opinion

The Ezra Klein Show

15,326 Listeners

The Weekly Show with Jon Stewart by Comedy Central

The Weekly Show with Jon Stewart

10,285 Listeners

2 Gurus Talk Compliance by Thomas Fox

2 Gurus Talk Compliance

5 Listeners