Compliance into the Weeds

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. This week, Matt and Tom take a look at the recent ECI report on the Differences Between Small, Medium And Large Enterprises E&C Programs. Highlights include:·      Where did this ECI report derive its data?·      Why are middle sized companies in such bad condition regarding compliance program?·      Why are middle sized companies having the most issues?·       When is the time for compliance SME at a company?  ·      When should a company institute robust internal controls?Resources Matt in Radical ComplianceECI Report - Differences Between Small, Medium And Large Enterprises E&C Programs 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. This week, Matt and Tom take at the recent remarks by DOJ Assistant Attorney General Kenneth Polite on CCO certifications of compliance programs after the conclusion of a DPA. Highlights include:·      Where did this issue come from?·      Is its implementation looming?·      What are the implications for individual CCO liability?·       What about CEO liability for recidivism?  ·      What are the corporate governance implications?Resources Text of Kenneth 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. This week, Matt and Tom take a look at the proposed SEC climate change risk disclosure regulations released on Monday. Highlights include: The history of this issue. Is the SEC over-reaching? Why climate change regulations only? What about a broader set on ESG? The role of internal controls, audit and oversight.  What does all this mean for the compliance function? ResourcesMatt Kelly 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. This week, Matt and Tom visit with our Ukrainian colleague Tim Khashinov-Batirov. Tim is well-known in the worldwide compliance community as Compliance Man. He is currently a refugee in The Netherlands at the time of this recording. In this episode, Tim talks about his escape from Ukraine, what life has been like as a displaced person in Europe, the current and burgeoning refugee crisis and some things that we in America can do right now to help those still in Ukraine and those who are refugees. Other topics we consider include:·      How the bonds of brotherhood between Russia, Belarus and Ukraine may have been permanently destroyed?·      What do ordinary Russians think about the invasion?·      Armies like companies run on culture. Why and how has the corruption in the Russian Army hollowed out its culture from the inside?·       The leadership of President Zelensky and his impact on the Ukrainian people.  ·      The negative leadership of Russia President Putin.Resources for Donations for Ukraine and UkrainiansUNICEFSalvation ArmyRed Cross 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. This week, Matt and Tom take look at a recent speech by SEC Commissioner Alison Herron Lee where she considered the role of lawyers as gatekeepers under SOX 307. Some of the issues we consider ·      Who do lawyers represent?·      What is the difference between lawyers and gatekeepers?·      How can or should lawyers represent multiple interests on SOX issues?·       How does this comport with state bar requirements? ·      How, if at all, does SOX 307 impact compliance professionals?·      Was the speech a policy change announcement, trial balloon or something else. ResourcesMatt in Radical ComplianceSOX 307 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. This week, Matt and Tom take a somewhat somber view on the Russia invasion of Ukraine. Some of the issues we consider: Discussion of sanctions. What do sanctions mean for US, UK and EU countries? How companies should think about doing business in Russia going forward. What about energy production and consumption? US company employees in Ukraine and Russia. The role of China in a potential resolution. ResourcesTom in the FCPA Compliance and Ethics BlogMatt 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. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider Background facts and a corrupt culture, literally from the top. How does the SEC have jurisdiction over KT Corp? Why you need a flow chart of the bribery schemes and a scorecard of the players. Corruption leading to the Korean Blue House. Bags of cash delivered and kept in office safes. Was the resolution an interim step before a monitor is employed? ResourcesTom with a 3-part series in the FCPA Compliance and Ethics BlogMatt 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. This week, Matt and Tom return to one of Matt’s favorite topics Elon Musk/Tesla. Some of the issues we consider:·      What happens when a business is lead by a runaway CEO?·      Implications of new SEC investigation.·       State of California investigation into racial discrimination. ·      Where has the Board been all this time?·      Will the attitude of the SEC regarding enforcement change? 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. This week, Matt and Tom take up two recent academic papers which every compliance practitioner should study as they provide insight about how communications can impact both fraud prevention and compliance. Some of the issues we consider Berger and Lee on state FCA claims cutting overall accounting fraud. Jinjie Lin on SEC tweeting and reduction of SEC violations. What do these communication strategies portend? How can they be used by the compliance professional? Why whistleblowing does more than simply prevent fraud, waste and abuse. If improves the bottom line. Investment in communications strategies pays off? 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. This week, Matt and Tom are pleased to host Mike Volkov, host of the Corruption Crime and Compliance podcast on the Compliance Podcast Network. Mike formerly worked in the DOJ, Antitrust Division. We consider the current evolution of antitrust enforcement by the DOJ and FTC and how it might impact the Microsoft acquisition of Activision Blizzard. Some of the issues we consider include:·      Is the focus of antitrust enforcement changing from consumers to others?·      What is a Section 2 Sherman Act claim?·       What are structural v. behavioral remedies? ·      Have partial divestitures fallen out of favor?·      How might all this play out in the Microsoft acquisition of Activision Blizzard?·      What is the role of compliance going forward?ResourcesMatt in Radical ComplianceMike Volkov in  Corruption Crime and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices