Compliance into the Weeds

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. In this special 300th Anniversary episode, we consider a recent academic paper which suggests that policies play a small role in persuading employees not to engage in bribery and corruption. Highlights include:·       What did the paper conclude?·       What is the role of procedures?·       Tom details the one function of policies.·       How does an operationalized compliance program work?·       What is the intersection of policies and internal controls? ResourcesMatt in Radical Compliance 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. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include:·       What are clawbacks?·       What does the SEC rule require?·       Are clawbacks the mirror of executive incentives?·       How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements?·       How far down the corporate chain must a clawback provision impact? ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog 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. In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. Highlights include:·       What are the background facts?·       What were the bribery and payment schemes?·       What are the compliance lessons learned?·       How will the victim status play out?·       Who will guarantee the compliance of Lafarge with the Plea Agreement. ResourcesTom in the FCPA Compliance and Ethics Blog 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. In this episode, we consider the recent statement by Paul Munter, the SEC’s acting chief accountant, where he urged auditors to do better at assessing fraud risk among their clients. Highlights include:·       Why did the SEC raise these points in the first place? What are they trying to tell auditors that they’re doing wrong?·       Are auditors really equipped to be more aggressive in fraud risk assessment and investigation?·       What should compliance officers be thinking about vis a vis the SEC’s statement? ·       What is the role of compliance in in anti-fraud?·       How will this impact compliance audits by external auditors and fraud examiners? ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

Now 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. In this episode, we look at burgeoning scandal from north of the border in Hockey Canada. Highlights include: What happens when your sport is also your national religion? How can you affect a change across an entire sports culture. Who are your stakeholders and are you protecting them? The Wide World of Sports misconduct. When (and if and how) will management start to listen?  ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include: Recidivist behavior in same countries with similar schemes. Policy, procedure and internal controls failures. Why no monitor. Compliance programs lessons learned. What about the DOJ?  ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog Background The Schemes in Action Parking in India The Comeback and DOJ What it all means Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships.  ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors The heat is on Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include:·      What are clawbacks and how would they work in practice?·      Does a lack of corporate clawbacks lead to aggravating factors?·      How much credit will a company receive by instituting clawbacks?·      CCO certifications are here to stay.·      How does the Polite Speech relate to the Monaco Memo. ResourcesMatt in Radical ComplianceText of Polite Speech Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the implementation of a national suicide prevention hotline, 988 and consider what it might teach compliance professionals.  Highlights and questions posed include:·      What is the new national Suicide Prevention hotline? ·      How does it inform your corporate hotline and speak up culture?·      How do you teach the trait of listening?·      Engaged employees are more effective employees.·      How easy are the mechanics of your hotline to navigate. ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we mine the whistleblower allegations by Peiter Zatko, AKA “Mudge” made against Twitter for lessons for the cyber-security professional and wide compliance discipline.  Highlights and questions posed include:·      The allegations made by Mudge. ·      Why does an organization need a CISO (or CCO or CECO)? ·      How did Twitter get hacked, its employees duped and its controls by-passed?·      What is pedestrian yet telling in this saga?·      Why data mapping is mandatory if not critical?·      Where were the external auditors?·      Is there a Caremark claim here?ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices