169 episodes

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. 

Compliance into the Weeds Tom Fox

    • Management
    • 5.0 • 6 Ratings

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. 

    The Deutsche Bank FCPA Settlement

    The Deutsche Bank FCPA Settlement

    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 consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.
     Some of the issues we consider are:

    The Bank’s compliance program was a paper program only.

    Where was compliance?

    What Red Flags were missed?

    Internal Audit did its job but was ignored.

    Actual Knowledge of corruption?

    What about the DFS?

    Resources
    Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:
    Part 1-Introduction
    Part 2- The Bribery Schemes
    Part 3- Overlooked Red Flags and Internal Control Failures
    Part 4-Recivist Penalty
    Part 5-Final Thoughts
    Matt’s blog post in Radical Compliance:
    Deutsche Bank Control Failures Cost $130 million
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    • 27 min
    5 Issues for Compliance Professionals in 2021

    5 Issues for Compliance Professionals in 2021

    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 consider five issues that compliance practitioners need to watch in 2021. We also talk about the second five which did not make the Top 5 but you still need to watch. 
    Some of the issues we consider are:

    What will be the implications of the Covid-19 vaccine and RTW?

    The Anti-Money Laundering Law of 2020.

    The first Biden Administration announcement.

    Climate Change Disclosures.

    The SolarWind Cybersecurity Disaster.

    A special bonus from Matt.

    Resources
    For more information see Matt’s blog post in Radical Compliance:
    Five Compliance Events to Watch in 2021
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    • 33 min
    Who Should Oversee and Manage the Hotline

    Who Should Oversee and Manage the Hotline

    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 consider the question of who in an organization should oversee a hotline. Once that decision is made, who should manage the hotline.
     Some of the issues we consider are:

    Why the Audit Committee on the Board should oversee the hotline.

    It should be written into the Audit Committee’s Charter.

    The hotline manager must have the independence to investigate any issues raised and they must have the competence to do so.

    Why the Compliance Function should oversee management of the hotline.

    Resources
    For more information see Matt’s blog post in Radical Compliance:
    Who Should Run the Hotline?
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    • 22 min
    Algorithm Failures in Ethics and Equity at Stanford

    Algorithm Failures in Ethics and Equity at Stanford

    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 consider how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations. Stanford used a faulty algorithm which mandated that only seven of the Health Systems 1300 medical residents would receive the vaccine. As you might guess these front-line health workers were up in arms over Stanford’s incompetence on this issue.
    Some of the issues we consider are:

    The plan had been for the algorithm to assign vaccination slots for the first 5,000 employees, who would begin receiving the Covid vaccine on Dec. 18.

    What were the parameters of the algorithm?

    Why was there so little ethics in the process?

    Why was there so little equity in the result?

    What are the implications for the compliance professional of the use of the algorithm to make such a critical decision?

    What does the EEOC decision allowing companies to mandate vaccines for employees mean for compliance?

    Resources
    For more information see Matt’s blog post in Radical Compliance:
    Lessons on Algorithms, Ethics and Equity
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    • 22 min
    Leadership Failures at Ft. Hood, with Special Guest Diane St. Ives

    Leadership Failures at Ft. Hood, with Special Guest Diane St. Ives

    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:

    What were and are the continuing failures of leadership at Ft. Hood in these areas?

    Why is the SHARP program simply window dressing?

    What will it take to make a change?

    Our Guest Diane St. Ives relates her personal experience of being sexually harassed over 40 years ago while a Private at Ft. Hood. She talks about the retaliation she received for reporting the crime and how it all still affects her today.

    What can be some of the solutions for this situation and how can compliance principles help turn around a continuing culture of misogyny in the Army.

    Resources
    For more information see Matt’s blog post in Radical Compliance:
    Leadership Failures at Ft. Hood
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    • 25 min
    NDAA Creates New Whistleblower Law

    NDAA Creates New Whistleblower Law

     
    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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    • 22 min

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