Compliance into the Weeds

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. Are you seeking insightful perspectives 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 COSO Corporate Governance Framework. Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework's six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft. Key highlights: Overview of COSO's Draft Corporate Governance Framework The Six Objectives of the Framework Importance of Culture in Compliance Principles and Points of Focus Resilience in Corporate Governance Resources: Matt Kelly 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. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you seeking insightful perspectives 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 memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump's executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA 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. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly consider what happens when AI turns whistleblower. The advent of AI technologies, such as Claude Opus 4, has sparked debates over the potential for AI systems to autonomously report misconduct, presenting new ethical and operational challenges within AI governance. Tom Fox views AI whistleblowing with caution, questioning the feasibility of implementing effective governance rules and the complexities involved in distinguishing between AI-generated reports and those of human whistleblowers. His concerns are shaped by the legal and ethical implications of AI's autonomous actions, highlighting a pressing need for clearer regulations. Similarly, Matt Kelly is concerned about the ethical nuances, emphasizing the difficulty AI might face in understanding corporate ethics and compliance culture without human oversight, and underscores the urgent need for regulatory frameworks to keep pace with the advancements in AI. Fox and Kelly's perspectives converge on the necessity for robust oversight mechanisms and strategic planning to manage the compliance challenges posed by AI in whistleblowing scenarios. Key highlights: Autonomous AI Reporting Misconduct to Authorities Navigating AI Ethics for Regulatory Compliance Distinguishing AI Reporting in Whistleblower Cases Navigating AI Challenges in Compliance Programs Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 and seeking insightful perspectives on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the Department of Justice's recent proposal to grant Boeing a non-prosecution agreement. This decision stems from the 737 MAX crashes in the late 2010s that killed 346 people. They cover the history of Boeing's settlements, the details and leniency of the new agreement, the role and scope of the independent compliance consultant, and the implications for corporate compliance and the victims' families. The discussion highlights the potential end of compliance monitors and the broader impacts on corporate accountability. Key highlights: DOJ's Non-Prosecution Agreement with Boeing Changes in the Settlement Agreement Role and Scope of the Independent Compliance Consultant Implications for Compliance Monitorships Boeing's Whistleblower Program and Compliance Efforts Judicial and Victims' Family Reactions Resources: 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. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this episode of Compliance into the Weeds, Tom Fox and Matt Kelly deeply dive into a recent tweet by President Donald Trump targeting Walmart and their announced intention to raise prices based on increased tariff costs. The discussion explores the implications of Trump's demand that Walmart absorb tariff costs instead of passing them on to consumers. It examines the broader implications for stakeholder capitalism, the role of presidential influence on corporate governance, and the complexities of risk management in an unpredictable political climate. The episode also touches on ESG issues and the delicate balance companies must strike in navigating these challenges. Key highlights: Trump's Tweet and Walmart's Dilemma Stakeholder Capitalism vs. Shareholder Primacy Corporate Governance and Presidential Influence Legal Implications and Corporate Compensation Risk Management in Unpredictable Times Resources: 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, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this Compliance into the Weeds episode, Tom Fox and Matt Kelly deeply dive into the potential gift of a luxury Qatari jetliner to President Trump. We discuss the launch of Trump's meme coins and the Qatari government's allegedly planned $400 million plane donation to Trump. The conversation examines the compliance and corruption risks these actions pose for U.S. and international businesses. Kelly emphasizes how these incidents challenge ethical standards and underscore the importance for companies to address new forms of corruption proactively within their anti-corruption programs. Key highlights: Trump's Alleged Corruption: An Overview The Meme Coins Controversy The Qatari Plane Donation Compliance and Integrity in the Face of Corruption Resources: 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, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the declination recently given by the DOJ to the Universities Space Research Association (USRA). In this episode, Tom and Matt dive deeply into a recent decline issued by the Department of Justice (DOJ) to the University Space Research Association (USRA). The discussion focuses on the organization's exemplary behavior in self-disclosure and cooperation during an investigation into an employee's misconduct. This misconduct included unauthorized export of software to Beijing University. The hosts highlight the case as a textbook example of effective compliance practices, self-reporting, and cooperation with regulators. They also explore the DOJ's guidelines on self-disclosure and the importance of internal controls in high-risk areas. Key highlights: Case Overview: USRA Declination DOJ Press Release Insights Details of the Misconduct USRA's Response and Cooperation Resources: DOJ Press Release on Universities Space Research Association Declination Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you 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 take a deep dive into the settlement of charges by the OCC with two former top audit executives at Wells Fargo for their oversight failures during the bank's fake accounts scandal. The Wells Fargo banking scandal is a cautionary tale of unchecked corporate misconduct and the critical role of auditor accountability. This scandal, which erupted due to Wells Fargo's creation of fake accounts driven by unrealistic sales targets, exposed the bank's dysfunctional corporate culture and raised questions about the efficacy of internal audits and the broader implications of regulatory actions. They discuss the scandal as emblematic of the broader issues stemming from repealing the Glass-Steagall Act, which blurs the lines between investment and consumer banking, fostering an environment where misconduct could thrive. Kelly points to the enormity of banks' post-Glass-Steagall repeal as a breeding ground for potential misconduct and highlights the negligence of Wells Fargo's leadership in failing to curb unethical practices. Both Fox and Kelly underscore the necessity for a comprehensive reevaluation of compliance and audit roles to prevent future scandals of this magnitude. Key highlights: Settlement of OCC Charges in Wells Fargo Impact of Regulatory Actions on Auditors Unethical Sales Goals Impacting Corporate Culture Glass Steagall Act Repeal: Wells Fargo Impact Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the future role of compliance monitors in the corporate world under the Trump administration. Despite the potential for changes, federal prosecutors are expected to continue using compliance monitors as a critical tool. However, the criteria for assigning these monitors may become more limited. The episode critically examines the trustworthiness of statements from the Trump administration and its Justice Department, emphasizing the uncertainty facing corporations and compliance professionals moving forward. Key highlights: Trump Administration's Stance on Monitors Criteria for Assigning Monitors Skepticism Towards Statements Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the critical yet often overlooked aspects of data analytics. They discuss Matt's recent blog post on the ‘Unsexy Keys to Data Analytics,' emphasizing the importance of foundational infrastructure over flashy visualizations. The conversation covers the need for robust data validation, the cooperation between compliance, business units, and IT departments, and the challenges faced by compliance officers in smaller companies. Highlights include real-world examples, the role of data governance, and how to align compliance risk management with corporate objectives amid ever-changing business landscapes. Key highlights: The Importance of Data Infrastructure Compliance vs. Enterprise Data Analytics Collaboration Across Departments Data Governance and Change Management Aligning Compliance with Corporate Risk Management Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you 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 take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement. Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations. They explore the dual excitement and anxiety surrounding AI's role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency. Key highlights: The Future of Compliance Post-Executive Order The Role of Technology in Compliance AI's Impact on Compliance Officers Strategic Imperatives for Compliance Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly are joined by Mary Inman, a founding partner at Whistleblower Partners. Matt, Tom, and Mary reflect on the global response to anti-corruption measures following an executive order issued by former President Trump. The conversation highlights webinars conducted in early 2025 that addressed concerns over who would enforce anti-corruption laws worldwide if the United States stepped back. The sentiment among countries like Brazil, Hong Kong, Singapore, England, and France was clear; they were ready to take on the mantle themselves. Mary reports on her conversations with the SFO in London about instituting a whistleblower program and similar initiatives in the United Kingdom at His Majesty's Revenue and Customs and the Financial Conduct Authority. Key highlights: Global Anti-Corruption Sentiment Post-Trump's Executive Order Encouraging International Enforcement Evidence of Global Enforcement Actions Whistleblower Incentives in the UK Global Leadership in Anti-Corruption Resources: Mary Inman on LinkedIn Whistleblower Partners Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the issues surrounding employee leaks of confidential information, drawing on insights from a recent SCCE Europe event. They also consider the motivations behind such leaks, including dissatisfaction with corporate culture and ineffective internal reporting channels, exemplified by the recent leaks at Facebook. The episode reviews measures compliance officers can take to prevent leaks, such as implementing tight access controls, encryption, and improving communication during investigations. Practical tips for reducing leaks and the importance of trust in internal reporting are also highlighted. Key highlights: Discussion on Employee Leaks Facebook's Toxic Culture (or not) and Leaks Addressing Internal Speak-Up Culture Practical Tips to Prevent Leaks Modern Communication Challenges Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss additional compliance issues raised by the current administration. The first involves the Trump Administration investigating environmental groups receiving EPA grants. While both believe the investigations are politically motivated, they highlight the need for a robust compliance program, documentation of that program in practice, and transparency with stakeholders. The second example is the Democratic Republic of Congo's offer to the Trump administration for mineral extraction rights, raising concerns about navigating FCPA compliance amid high corruption risks. The episode underscores the importance of robust compliance capabilities to handle unpredictable regulatory environments and emerging risks. Key highlights: Compliance Issues under the Trump Administration Environmental Groups Under Investigation The Democratic Republic of the Congo Deal Compliance is the Answer Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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 Compliance into the Weeds episode, Tom Fox and Matt Kelly discuss a recent conference Matt attended that delved into compliance and the compliance profession in the Age of Trump II. Their discussion highlighted insights from a recent compliance panel hosted by Suffolk University Law School, featuring experts from large tech companies, a multi-state credit union, and a partner from a private law firm. The consensus among these experts is that despite the change in administration, the fundamental responsibilities and importance of compliance remain largely unchanged for organizations. Compliance is now deeply embedded in business operations, key in managing vendor risk, ensuring data protection, and upholding ethical standards. Matt emphasizes that compliance capabilities are vital when dealing with other companies, whether they are customers or vendors. The conversation explores the convergence of vendor risk management and ethics & compliance programs and examines how organizations can sustain their integrity and manage emerging risks. Matt and Tom touch on the potential impact of new regulations, the importance of internal stakeholders in the compliance process, and the necessity of maintaining a robust risk management framework in an ever-changing regulatory environment. This episode provides valuable insights for compliance officers navigating the complexities of the modern corporate landscape. Key highlights: Compliance in the Trump Administration Vendor Risk Management Impact of Tariffs on Compliance Who Are We as a Company? Managing Regulatory Uncertainty Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recently released 2025 E&C Program Effectiveness Report (Report) from LRN and deeply dive into its findings of a disconnect between top management and employees on ethics and compliance. Tom and Matt examine the significant findings of the LRN survey conducted among over 1,500 ethics and compliance professionals, which formed the basis for the 2025 Report. They emphasize the widening perception gap about corporate ethical culture between senior executives and lower-level employees and discuss the importance of transparency, consistent disciplinary measures, and engagement of frontline employees to bridge this divide. Matt and Tom also address compliance officers' challenges in assessing their organizations' ethical culture and suggest practical steps for fostering a more cohesive environment. Key highlights: Key Findings from the LRN Report Assessing and Addressing the Perception Gap Building Trust and Transparency Involving Employees in Policy Design Engaging with Employees and Building Community Resources: Matt in Radical Compliance LRN 2025 E&C Program Effectiveness Report Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recent astonishing developments at the Justice Department involving the indictment and subsequent attempted dismissal of charges against New York City Mayor Eric Adams. Tom and Matt explore the implications for corporate compliance professionals and the broader message this dysfunction sends about ethics and the role of compliance programs under the current administration. They consider the possible repercussions for future corporate enforcement, drawing important parallels between the Justice Department's actions and the expectations for corporate compliance. They emphasize the necessity of disentailing the ethical dysfunction at the department from the practical guidelines for compliance programs. The episode critically analyzes how political maneuvers affect the justice system and corporate compliance standards. Key highlights: The Eric Adams Indictment Resignations and Internal Conflict Separating DOJ Integrity from Compliance Guidance Tone at the Top vs. Mood at the Middle Future of Compliance Guidelines Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the Trump Administration's attempts to end enforcement by the CFPB and corruption under the FCPA. Last week, significant alterations were made to enforcement policies related to the Foreign Corrupt Practices Act (FCPA) and the Consumer Financial Protection Bureau (CFPB), resulting in a noticeable reduction in enforcement efforts and a shift in focus towards issues like corporate bribery associated with drug cartels and human trafficking. These actions will create risks for U.S. businessmen in countries like China, who might face false charges due to the de-emphasis on traditional FCPA enforcement, and these policy shifts might expose U.S. companies to anti-corruption investigations leveraged by other countries in retaliation to Trump's trade policies. Matt Kelly emphasizes the need for businesses to maintain robust compliance programs despite the enforcement rollback, warning that legal risks remain due to the statute of limitations, and stresses the importance of upholding corporate compliance and ethical standards to prevent corruption. Through their extensive experiences in compliance and corporate governance, both Tom and Matt highlight the complexities and potential repercussions of these enforcement changes on global business operations. Key highlights: Introduction: Unpacking the Current Situation Emphasis on Corporate Bribery in Enforcement Changes Upholding Compliance Duties Amid Enforcement Changes FCPA and CFPB Statute of Limitations Global Business Impact of Trump's Trade Policies Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly explore why compliance officers are uniquely suited for public office. Tom and Matt discuss the inspiring story of Doran Clark, a Medtronic compliance officer recently elected Democratic state senator in Minnesota. This event sparked a larger conversation about why compliance professionals possess a unique skill set that could greatly benefit public office. Matt and Tom consider the various competencies of compliance officers, such as persuasion, investigation, policy development, and ethics, which are highly valuable in governance. The discussion highlights the role of compliance officers in fostering good conduct and ethical behavior within organizations, skills that can translate well to public service. They emphasize the importance of collaboration, resource allocation, and effective communication, competencies that are often lacking in today's political climate. The episode concludes with Matt encouraging more compliance professionals to consider running for public office and the possibilities they bring for positive societal change. Key highlights: The Skill Set of Compliance Officers Challenges and Real-World Applications Local Governance and Compliance Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore the Trump Administration's summary of the Friday night firing of 17 US Inspector Generals. They explore the background and illegality of these firings, highlighting the critical role Inspector Generals play in the federal government by investigating fraud, mismanagement, and abuse. Furthermore, they discuss the implications for compliance professionals, comparing this situation to what would be deemed unacceptable in corporate settings. The conversation also touches on potential consequences, such as increased False Claims Act lawsuits and the problematic precedent set for the rule of law within federal agencies. Key highlights: The Friday Night Massacre: What Happened? Role and Importance of Inspectors General Comparisons to Corporate Governance Potential Consequences and Future Outlook Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore a significant enforcement action by the Conference of State Bank Supervisors (CSBS) against Block Inc. They discuss the CSBS's role as a collective of state banking regulators, the reasons behind the $80 million fine imposed on Block, and the extensive compliance reforms the company must implement, including appointing an independent consultant. They consider the broader implications of state-level enforcement actions in areas like anti-money laundering and data privacy, especially in light of potential shifts in federal regulatory priorities. Matt and Tom consider how compliance professionals can adapt by bolstering transparency, forming compliance committees, and staying abreast of the evolving regulatory landscape. Key highlights: Understanding the CSBS and Block Inc. Enforcement Implications of State-Level Enforcement Comparative Enforcement Actions Challenges for Compliance Professionals Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly delve into JP Morgan Chase's treatment of employees who commented on the bank's Return to the Office policy. JP Morgan's recent decision to require employees to be back in the office five days a week caused the bank to disable employee comments on the internal announcement, citing backlash. Tom and Matt explore the implications this has on workplace respect, speak-up culture, and employee morale, juxtaposed with the compliance officer's role in measuring and maintaining corporate culture. They also detail how these corporate policies might reflect broader trust issues and potential fallout from a discontented workforce. Additionally, the episode revisits Meta's (formerly Facebook) recent rollback on DEI initiatives and its promotion of a more ‘freewheeling' speech environment, considering the ethical and compliance ramifications of such a culture shift. The hosts compare these actions to other reported corporate behaviors that may undermine workplace respect and discuss the fragile balance a Chief Compliance Officer must maintain in fostering a fair and open workplace compliant with evolving societal norms and internal policies. Key highlights: JP Morgan's Return to Office Policy Employee Reactions and Speak Up Culture Ethics and Compliance Implications Workplace Respect and Culture Meta's Policy Changes and Corporate Culture Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In the first episode 2025, Tom and Matt dive into the top compliance stories that could shape the upcoming year. They begin with the politically charged corruption case involving Gautam Adani, discussing its implications under the Trump administration and the potential for the Justice Department to alter its course on this high-profile prosecution. They also explore the possibility of personal liability in the TD Bank compliance scandal, the anticipated policy shifts under SEC nominee Paul Atkins, and the future of the Consumer Financial Protection Bureau (CFPB) under a Republican administration. Additionally, they address the challenges and potential impact of the DOJ Committee's deregulation efforts and the unresolved Boeing Deferred Prosecution Agreement case's monitorship issues. Tune in to understand what compliance officers should be watching for in 2025, as these stories could have significant ramifications for corporate compliance and enforcement practices. Key highlights: Top Compliance Stories of 2025 Gautam Adani Corruption Case TD Bank Compliance Scandal Paul Atkins and the SEC Future of the CFPB DOGE Committee and Deregulation Boeing Monitorship Controversy Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the intricate and unusual story of the National Rifle Association (NRA) and its recent corporate governance overhaul. Matt and Tom explore Judge Joel Cohen's final ruling, which mandates extensive corporate governance reforms for the NRA. These reforms address significant issues, such as a structurally weak board, poor financial controls, and an overpowering CEO in Wayne LaPierre, who misused the organization's resources. Necessary measures discussed include revamping the board's audit committee and introducing annual compliance reports, along with significant protections for the role of the Chief Compliance Officer. The episode highlights the universal principles of good governance, asserting that the NRA's reforms can serve as a valuable lesson for other organizations. Regardless of the political or ethical stance on the NRA's activities, the implemented governance structures underscore the necessity of transparency, an empowered compliance function, and robust oversight mechanisms to prevent misuse of organizational resources. These insights are illustrated through sample agreements and templates in the court ruling, which can guide other organizations in strengthening their governance and compliance programs. Key highlights: Corporate Governance Reforms Ordered by the Court Specifics of the Court-Ordered Reforms Audit Committee and Board Reforms Compliance and Governance Templates Universal Principles of Good Governance Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into a potpourri of issues, including Paul Atkins's appointment to chair the SEC, a massaging of DOJ and the Corporate Enforcement Policy, and McKinsey's FCPA resolution. Tom and Matt discuss various compliance issues, focusing on the implications of Paul Atkins' appointment as SEC chairman, the challenges of enforcement and corporate penalties, the role of whistleblowers, and recent FCPA enforcement actions, including the McKinsey settlement. They explore how Atkins' conservative views may shape SEC policies and the potential impact on compliance officers and corporate governance. Key highlights: Paul Atkins and the SEC Enforcement Challenges and Corporate Penalties Whistleblower Protections and Compliance Officers FCPA Enforcement and McKinsey Settlement Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the Trump Administration's DOGE initiatives and what it might mean for compliance. Tom and Matt discuss the implications of Elon Musk and Vivek Ramaswamy's Department of Government Efficiency Committee (DOGE), which aims to downsize the federal government drastically. They explore the potential consequences of cutting half of all regulations and federal employees, particularly on compliance officers and corporate risk management. The conversation highlights how the reduction or abolition of federal regulations would affect various sectors, including the military, social security, and essential services, and delves into the challenges this proposal poses for compliance programs within businesses. They also consider possible outcomes such as increased state-level regulations, civil litigation, and the chaos and uncertainty that might follow. Finally, they discuss how companies should prepare for an inconsistent and unpredictable regulatory environment under a Trump administration. Key highlights: DOGE and Government Restructuring Implications for Compliance Officers Challenges of Cutting Regulations and Staff Potential Consequences of Reduced Regulations and Non-Enforcement Compliance Embedded in Business Practices State-Level Regulation and Emerging Risks Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you 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 dive into the Trump Administration's DOJ nominees, FCPA enforcement going forward, and what it may all mean for compliance professionals. Tom and Matt explore the potential impacts of these nominations, notably the controversial choice of Matt Gaetz as Attorney General, and how they could shape the direction of anti-corruption enforcement and compliance practices. They also discuss the realistic aspects of other nominees, including Trump's attorneys Todd Blanche and Emil Bove and former SEC Chairman Jay Clayton, who proposed to lead the Southern District of New York. The conversation touches on potential strategies for compliance officers, such as the increased significance of self-disclosure and the broader ramifications for corporate and foreign policy enforcement under a Trump administration. Key highlights: Trump's DOJ Nominees: An Overview Potential Changes in FCPA Enforcement Self-Disclosure and Compliance Implications for Compliance Officers Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you 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 dive into the recently released FCPA enforcement action involving the Telefónica Venezolana subsidiary. They explore the bribery scheme used by Telefónica Venezolana to win an auction for U.S. dollars in 2014, resulting in a significant criminal penalty. The episode delves into the complexities of compliance in high-risk jurisdictions, the importance of incorporating anti-corruption due diligence into supply chains, and the implications of the new enforcement landscape under different administrations. Key lessons include the surprising extent of supplier risk, the long tail of FCPA enforcement, and the financial benefits of robust compliance practices. Key highlights: Details of the Bribery Scheme Consequences and Penalties for Telefónica Venezolana Compliance Challenges and Lessons Learned Risk Management in High-Risk Jurisdictions The Importance of a Robust Compliance Program Long-Term Implications of FCPA Violations Future of FCPA Enforcement Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this special election day episode of ‘Compliance into the Weeds,' Tom Fox and Matt Kelly dive into a lighter yet insightful compliance story involving a young boy named Danny Doherty. At 12 years old, Danny set up a homemade ice cream stand in Massachusetts to raise money for a hockey team for children with developmental disabilities. However, the local health department shut its stand down due to risks associated with homemade dairy products, highlighting the importance of a risk-based approach in compliance activities. Tom and Matt discuss key compliance lessons from this incident, such as the necessity of addressing real risks, the potential for compliance failures despite good intentions, and the importance of effective communication by regulators. Key highlights: The Story of Danny Doherty Compliance Lessons from Danny's Story Risk-Based Approach in Compliance The Importance of Communication in Compliance Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 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 events at the Washington Post, where the newspaper decided not to endorse a presidential candidate for the first time in years. This decision, directed by owner Jeff Bezos, has led to significant backlash, including 200,000 lost subscribers and concerns about the paper's principles. Matt and Tom discuss the implications of this move on leadership, company values, and stakeholder trust, providing insights into the governance structure of newspapers and the potential fallout of abandoning established principles. We also turn to company values and if you are going to violate them, there should be sufficient justification. Finally, what a second Trump Administration might mean for corporate compliance. Key Highlights: Washington Post's Controversial Decision Newspaper Governance Explained Washington Post's Mission and Principles Leadership Failures and Consequences Potential Future Implications Resources:   Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 RTX Foreign Corrupt Practices Act enforcement action. Their discussion unveils complex bribery schemes involving millions paid to Qatari agents and the family of the Emir to secure defense contracts. Despite strict regulatory oversight, Raytheon's (now RTX) compliance missteps spanned from 2012 into the 2020s, resulting in massive fines. Matt and Tom scrutinize these failures, detailing the SEC and DOJ's mandates for dual monitorships due to violations of the False Claims Act and FCPA and the Board's critical role in addressing these issues. Additionally, a comparative look at other significant FCPA cases, including Moog's penalties for bribery in India, highlights persistent corporate misconduct and the ongoing challenges in achieving effective corporate compliance. Key Highlights:  Overview of Raytheon's Violations  Qatari Agent and Further Corruption  Raytheon's Compliance Failures Management and Compliance Failures Board Oversight and Responsibilities  Reflections on Compliance and Enforcement Resources 1.    Blogs Matt in Radical Compliance 2.     Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties. In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank's compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank's strategy is a clear warning when a business puts profits over compliance.  Key Highlights ·      Introduction to the Flat Cost Paradigm ·      Details of the Budget Strategy ·      Impact on Anti-Money Laundering Efforts ·      Financial Growth Amidst Budget Constraints Resources   1.    Blogs Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog 2.     Tom   Instagram Facebook YouTube Twitter LinkedIn 3.    Enforcement Related Material A.    OCC OCC Press Release Consent Order  Civil Money Penalty    B.    DOJ   TD Bank US Holding Company Information TD Bank N.A. Information TD Bank US Holding Company Plea Agreement and Attachments TD Bank N.A. Plea Agreement and Attachments Merrick Garland Remarks Nicole Argentieri Remarks Learn more about your ad choices. Visit megaphone.fm/adchoices

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 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 study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance. The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success. Key Highlights: Overview of the Compliance Study Key Findings and Statistics Challenges in Compliance Testing Importance of Multiple KPIs Access to Data Issues Resources: Matt in Radical Compliance 2024 Benchmarking Study: Testing & Monitoring and Data & Systems Rethink Compliance   Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 2024 update to the Department of Justice's guidelines for corporate compliance programs, focusing on data and data access.  Tom and Matt explore the significance of these updates and whether they stem from companies showing advancements in data analytics or the DOJ recognizing gaps in data access for compliance officers. The discussion highlights the challenges compliance officers face, especially with diverse ERP systems and data silos, and provides insights into how compliance officers can leverage these guidelines to advocate for better data access within their organizations. The episode also breaks down specific questions from the DOJ's guidelines, offering practical advice on addressing obstacles to data, resources for data access, and data maintenance. Key Highlights ·      The Importance of Data Access in Compliance ·      Challenges in Data Access for Compliance Officers ·      DOJ's Six Key Questions on Data Access ·      Addressing Data Access Impediments ·      Tools and Resources for Data Analytics ·      Communicating with the Board on Data Analytics Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute.  Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ's increased scrutiny on companies speak-up cultures and the protection of whistleblowers. Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs.  Key Highlights ·      Key focus on enhancing whistleblower protections. ·      Compliance officers must ensure that reporting mechanisms are well-publicized. ·      Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training. ·      The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines. ·      The practical steps for compliance professionals to align their programs with DOJ's evolving expectations. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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

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 SEC enforcement actions against several companies for pre-taliation clauses and related illegal intent.   Our conversation discusses recent enforcement actions by the SEC sanctioned against seven companies for a total of $3 million in civil penalties. The main issue was that these contracts required employees to forfeit any right to whistleblower awards if they reported misconduct to regulators. The conversation explores the legality of these contract clauses and the chilling effect they have on potential whistleblowers. Tom and Matt also discuss the challenges of remediation and the need for a comprehensive approach to address retaliatory clauses in all types of contracts. Key Highlights SEC Enforcement Actions on Pre-Retaliation Language The Illegality of Pre-Retaliation Clauses Addressing Pre-Retaliation Clauses: Remediation Challenges Expanding the Focus: From Employment Contracts to All Contracts Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Check out the full 3-book series, The Compliance Kids on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

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 SEC enforcement actions against several companies for pre-taliation clauses and related illegal intent. Our conversation discusses recent enforcement actions by the SEC sanctioned against seven companies for a total of $3 million in civil penalties. The main issue was that these contracts required employees to forfeit any right to whistleblower awards if they reported misconduct to regulators. The conversation explores the legality of these contract clauses and the chilling effect they have on potential whistleblowers. Tom and Matt also discuss the challenges of remediation and the need for a comprehensive approach to address retaliatory clauses in all types of contracts. Key Highlights: SEC Enforcement Actions on Pre-Retaliation Language The Illegality of Pre – Retaliation Clauses Addressing Pre-Retaliation Clauses: Remediation Challenges Expanding the Focus: From Employment Contracts to All Contracts Resources: Matt in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 Department of Justice (DOJ) declination for the Boston Consulting Group (BCG). They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations. Key Highlights: Overview of the Boston Consulting Group Declination DOJ's Factors for Declination Full Cooperation, Timely Self-Disclosure and Employee Consequences Remediation Efforts and Compliance Improvements Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 question of whether a law degree is necessary for Chief Compliance Officers (CCOs).  Tom and Matt begin with a discussion of a recent compensation survey by Barker Gilmore that reveals CCOs with law degrees earn significantly more than their counterparts without JDs. They explore historical and practical reasons for this pay disparity and debate the actual necessity of a law degree for fulfilling modern compliance functions. Additionally, they identify key skills and functions essential for effective compliance and consider alternative career paths and educational backgrounds suited for aspiring compliance professionals. Key Highlights ·      The Value of a Law Degree for Compliance Officers ·      Breaking Down the Pay Disparity ·      Modern Compliance Demands ·      Career Paths and Skills for Compliance Officers Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 toxic workplace culture at Bank of America (BoA) around hours worked by junior employees, in spite of senior management saying the right things. BoA's investment banking division has long been plagued by a toxic work culture, characterized by overworked junior employees and severe health crises, despite repeated assurances of reform. Tom Matt discuss these pervasive issues within BoA's work environment. Fox highlights the tragic consequences of this toxic culture, such as the deaths of junior employees, and criticizes the company's failure to implement effective reforms, attributing this to a lack of accountability and ethical leadership. Kelly echoes this sentiment, emphasizing the necessity for senior management to set clear expectations and consequences for middle managers who perpetuate unethical behavior. Both stress the need for senior management to address the deep-seated cultural dysfunction, impose consequences, and foster a healthier, rule-abiding workplace to prevent further tragedies and promote employee well-being. Key Highlights: Toxic Workplace Culture at Bank of America Proactive Controls for Preventing Employee Overwork Consequences of Middle Managers in Corporate Culture Cultural Impact: Negative Attitudes in Organizations Resources: Matt in Radical Compliance How Bank of America Ignores Its Own Rules Meant to Prevent Dangerous Workloads, by Alexander Saeedy in the WSJ  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

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 some of the nettlesome internal challenges faced by many Chief Compliance Officers (CCOs) in today's corporate environment. On Compliance into the Weeds, Tom and Matt discuss the various challenges that CCOs face within organizations. They delve into stories of how senior management, particularly General Counsels (GCs) and Chief Financial Officers (CFOs), can sometimes undermine compliance efforts. The conversation explores issues such as budget cuts, restrictive vendor usage, structural impediments, passive-aggressive behaviors, and direct interference in investigations. They also consider potential solutions and strategies for CCOs to better navigate these struggles and ensure the effectiveness of compliance programs. Key Highlights: Budgetary Constraints and Sabotage Interference in Investigations Structural Impediments to Compliance Undermining by Engagement and Assignment Advice Going Forward Resources: Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices