Compliance into the Weeds

Tom Fox
  • 4.0 (15)
  • Management
  • Updated Weekly

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 Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance. 

  1. 1d ago

    Compliance Implications of DOJ’s New Fraud Division and McDonald Memo

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them in greater depth and uncover hard-hitting insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ’s “McDonald Memo.” This DOJ Memo outlines a new Trump administration fraud division that broadly claims jurisdiction over “all types of fraud,” potentially reshaping DOJ enforcement and creating uncertainty about overlapping authority with existing divisions (e.g., antitrust). They review five priority areas: a. public trust/financial integrity fraud (procurement, bid rigging, grants, social welfare), b. healthcare fraud, c. internal revenue fraud, d. global trade and commerce fraud (tariffs/customs), and e. an undefined “corporate misconduct” category. From a compliance perspective, they urge companies to reassess risk areas (healthcare, importers, and government contractors), strengthen third-party oversight and documentation, and “pressure test” compliance programs with transparency and recordkeeping. They also warn that politicized enforcement and unclear guidance—such as on cartel-related liability—complicate compliance strategy and may tempt leaders to treat settlements as a cost of doing business. Key highlights: McDonald Memo Overview Fraud Division Scope and Uncertainty Five Fraud Categories Explained Corporate Misconduct Questions Compliance Program Impacts Documentation as Defense Mexico Cartels and Strict Liability Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

    Compliance Implications of DOJ’s New Fraud Division and McDonald Memo

  2. Aug 12

    Ted Lasso, Culture and Compliance

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly celebrate the return of Ted Lasso for Season 4. Tom and Matt begin with why Ted Lasso resonates with compliance officers as a study of workplace dynamics, leadership, and building a culture of trust. They highlight how Ted focuses on coaching people and shaping club-wide culture through “thousands of imperceptible moments,” culminating in “total football,” where shared expectations and mutual support enable improvisation and performance. They connect this to compliance goals of embedding ethics so employees can handle new situations on the fly and to Jim Collins’ “level five” leadership and humility, illustrated by Ted renaming Trent Crimm’s book from “The Ted Lasso Way” to “The Richmond Way.” They also link the show to the military OODA loop (observe, orient, decide, act) as a model for empowered decision-making within clear objectives and boundaries and preview Season 4’s shift to Ted coaching a women’s team. Key highlights: Ted Lasso Returns Season Four Culture and Trust at Richmond Total Football and Compliance The Richmond Way Leadership Lesson Level Five Humility OODA Loop Meets Compliance Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

    Ted Lasso, Culture and Compliance

  3. Aug 5

    FinCEN’s $125MM UBS AML Order: A Culture and Resourcing Failure

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a newly issued FinCEN consent order sanctioning UBS Financial Services, the U.S. broker-dealer subsidiary of UBS. It is a $125 million penalty, the largest FinCEN fine against a broker-dealer, for extensive anti-money laundering failures. They highlight weak transaction monitoring and suspicious activity reporting (SAR) processes, poor customer due diligence, inadequate wire-transfer data collection, and data governance gaps that led to under-reporting and hindered FinCEN’s ability to build a complete money-laundering picture. The order notes UBS failed to monitor more than 50,000 foreign-currency wires totaling over $10 billion and did not disclose ongoing deficiencies discovered after a 2018 $14 million FinCEN action requiring fixes by 2021, with problems traceable back to 2004 and not addressed until 2023. They frame the matter as a tone-at-the-top and resourcing failure, compare it to other enforcement actions (including a recent SEC fine against Merrill Lynch), and suggest a future deeper dive after reviewing the full order. Key highlights: What UBS Got Wrong Scale Of The Failures Board Oversight and Resourcing Data Governance Breakdown SARs, Metrics, and AI Talk Takeaways and Next Steps Resources: ⁠USB Consent Order⁠  Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

    FinCEN’s $125MM UBS AML Order: A Culture and Resourcing Failure

  4. Jul 29

    Scoular Company FCPA Settlement: Cartel Links, Border Trade Risks, and Compliance Lessons

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent FCPA resolution with the Scoular Company. Both Tom and Matt have blogged on this matter, so check out the Resources link below for additional discussions. The recent FCPA enforcement action against Scoular Company involved a $10.2 million payment and a three-year deferred prosecution agreement over bribes by third-party customs brokers to Mexican border officials to expedite cross-border shipments. DOJ emphasized alleged cartel connections, including a strong statement from the U.S. Attorney for the Western District of Texas, which raised questions about expanded local U.S. attorney involvement and how cartel or potential FTO designations could heighten trade and compliance risks. The company received no voluntary self-disclosure credit but got a 25% discount, with remediation cited (including dropping brokers and strengthening tone at the top). They highlight off-channel WhatsApp use, the lack of released key documents (DPA, statement of facts, criminal information), and practical compliance takeaways on third-party oversight, data analytics, and risk assessments. Resources: Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Scoular Company FCPA Settlement: Cartel Links, Border Trade Risks, and Compliance Lessons

  5. Jul 15

    The Slaughter Ruling, Regulatory Volatility and a Healthcare Compliance Fraud Case

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it in greater depth. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the June 29 Supreme Court decision in Trump v. Slaughter. This decision upheld the president’s power to fire independent agency commissioners at will (with a carve-out for the Federal Reserve), overturning long-standing protections from Humphrey’s Executor. Kelly argues the ruling will politicize and degrade regulatory agencies, deter qualified minority-party commissioners, increase rulemaking volatility, and shift power away from Congress toward courts as rules are challenged. As an example, they cite the SEC’s proposal to allow semi-annual rather than quarterly reporting, which drew about 80,000 comments, with roughly 99% opposed, yet they predict it may proceed and later be reversed, creating compliance burdens. They then cover Georgia author Jean Wilson, sentenced to 10 years for a $66 million Medicare fraud scheme while writing healthcare compliance books. Key highlights: The Slaughter Ruling Regulatory Volatility Ahead Who Will Serve as Commissioners Fed Carve-out and Court Power Compliance Impact and No Easy Answers Healthcare Compliance Fraud Story (Or is it from The Onion?)  Resources: Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

    The Slaughter Ruling, Regulatory Volatility and a Healthcare Compliance Fraud Case

  6. Jul 1

    Survey Finds Widespread Retaliation Against Compliance Officers

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released Radical Compliance, Case IQ, and Compliance Week-sponsored survey of more than 325 compliance professionals quantifying retaliation against compliance officers. Matt reports that 70% say they have suffered retaliation (79% including those unsure), 67% experienced it more than once, and women report slightly higher rates than men. Common retaliation includes exclusion from meetings (64%), being badmouthed (59.5%), and unwanted role changes (49%), while 28% report being fired. Fear is significant: 36% are uncomfortable raising concerns at their current employer, and 48% have been stopped from doing so at some point. Among those reporting retaliation to management, the responses were poor: 53% saw no action, 21% saw investigations without a remedy, and only 4% felt management supported them. Few go to regulators or sue, though two-thirds of the small group who sued after firing reported satisfactory outcomes. They suggest structural protections such as disclosure of CCO departures, contract/termination safeguards like those in Indian banking rules, and updates to DOJ guidance. Key highlights: Headline Findings Key Stats Breakdown Types of Retaliation Career Impact Stories Protection Ideas Human Toll and Caveats  Resources Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Survey Finds Widespread Retaliation Against Compliance Officers

  7. Jun 24

    Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it in greater depth. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent Bosch export controls enforcement action involving two German subsidiaries that sold about $72 million in advanced microsensors and software to Huawei from 2020 to late 2024 Their actions violate U.S. export controls tied to the Foreign Direct Product Rule and 2020 “footnote one” restrictions. Although Bosch voluntarily self-disclosed, cooperated, remediated, disgorged profits, and received a DOJ criminal Declination, BIS imposed a $36.1 million civil penalty, citing fundamental compliance failures: an understaffed and underqualified export controls function, confusion between the de minimis rule and the foreign direct product rule (which has no de minimis exception), and mishandling repeated external warnings from business partners and suppliers. They highlight internal control and communication breakdowns (including external signals) and the need to build specialized export/sanctions compliance capacity, noting BIS issued a compliance framework in 2020 and offers training. Key highlights: Bosch case overview Understaffed compliance fallout Ignored partner warnings Declination and remediation COSO signals and controls Building export compliance muscle Resources Matt in Radical Compliance Tom in the FCPA Compliance Blog: Part 1, Part 2, Part 3, Part 4, and Part 5 posts on Thursday, June 25. Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

    Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

  8. Jun 17

    OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank

    The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it in greater depth. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action fining FTI Consulting $1.05 million for a sanctions violation involving indirect dealings with Russia’s state-owned VTB Bank. FTI provided economic analysis for VTB in litigation, but, knowing VTB was sanctioned, used a law firm as an intermediary to invoice and receive payment, which OFAC said does not avoid liability because prohibitions apply to indirect transactions as well as direct ones. OFAC doubled the base penalty of $525,000 explicitly to promote future compliance by similarly situated companies, signaling strong disapproval of “middleman” structures. The case also involved unpaid invoices that became an impermissible extension of credit to a sanctioned entity, highlighting the need for rigorous contract and payment-term review beyond basic sanctions screening and for dedicated sanctions expertise. Key highlights: Introducing the OFAC Case Middleman Billing Scheme Why Screening Misses Indirect Risk Did Compliance Approve It? OFAC Expectations and Capability Penalty Doubled Warning Shot Unpaid Invoices as Credit Extension Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

    OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank
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Ratings & Reviews

4
out of 5
15 Ratings

About

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 Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance. 

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