

Compliance into the Weeds
Tom Fox
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.
Episodes
Mentioned books

Jul 14, 2021 • 21min
FINRA Enforcement Actions involving Robinhood
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 deep dive into the two recent FINRA enforcement actions involving the trading platform Robinhood. Some of the issues we consider are:
What were the underlying facts?
Were red flags missed, consciously avoided or outright ignored?
Where was compliance?
Why must the human element always be present in compliance?
Why business continuity is really a compliance issues.
What about the IPO?
ResourcesMatt in Radical ComplianceLessons from Robinhood Learn more about your ad choices. Visit megaphone.fm/adchoices

Jun 30, 2021 • 28min
The Amec Foster Wheeler FCPA Enforcement Action
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 deep dive into the first FCPA enforcement action involving a company in 2021, the Amec Foster Wheeler global anti-corruption enforcement action. Some of the issues we consider are:
What were the underlying facts?
Were red flags missed, consciously avoided or outright ignored?
Where was compliance?
How corrupt was the culture of Foster Wheeler?
What does this mean for compliance going forward?
ResourcesMatt in Radical ComplianceFoster Wheeler’s FCPA LessonsTom in the FCPA Compliance and Ethics BlogNot a Siren’s SongSilk Shirts and CorruptionBa-da-Bing; Ba-Da-Bing Learn more about your ad choices. Visit megaphone.fm/adchoices

Jun 23, 2021 • 16min
Disclosures of Cyber Security Disclosure Failures
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 deep dive into a lesson learned long ago by the Nixon Administration, adapted for 21st century cybersecurity. It’s not just the breach, it is not disclosing the breach to authorities and investors for which companies get in hot water. Some of the issues we consider are:
What are your reporting obligations after a breach?
Why is the SEC interested in how you inform investors?
Why does the legal department want to hide any breaches?
What are the costs for failure to disclose?
What does this mean for compliance going forward?
ResourcesMatt in Radical ComplianceExample of Cybersecurity Disclosure Failures Learn more about your ad choices. Visit megaphone.fm/adchoices

Jun 16, 2021 • 20min
Financial Crimes Compliance Costs
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 deep dive into the recent report from LexisNexis Risk Solutions about the costs of financial crimes compliance and its implications for ABC compliance professionals. Some of the issues we consider are:
What costs have gone up?
Why have the costs for financial crimes compliance increased?
What areas are the costs centered?
Did the costs increase due to the pandemic?
What does this mean for other compliance disciplines going forward?
ResourcesMatt in Radical ComplianceFinancial Crimes Compliance Cost Keeps Going Up LexisNexis Report - True Cost of Financial Crime Compliance Global Report Learn more about your ad choices. Visit megaphone.fm/adchoices

Jun 9, 2021 • 24min
PCAOB Clean Sweep
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 deep dive into the SEC Chairman Gary Gensler’s firing of the entire PCAOB Board, including Board Chair William Duhnke. Some of the issues we consider are:
What does this mean for internal audit?
What does this mean for compliance?
What was the legal basis for these terminations?
How did Duhnke create such a toxic culture at the PCAOB?
What does this mean for ESG, cybersecurity and data analytics going forward?
ResourcesMatt in Radical ComplianceThe PCAOB House-Cleaning and You Learn more about your ad choices. Visit megaphone.fm/adchoices

Jun 2, 2021 • 26min
Compliance and ESG
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 deep dive into the role(s) of compliance for ESG. Some of the issues we consider are:
How compliance is most suited to lead a corporate ESG effort.
Why compliance must do so or be relegated to a technical function?
How does government, the courts and investors drive ESG?
What is the role in asymmetrical regulations in driving ESG?
Why was last week such a wakeup call for corporations around ESG?
ResourcesMatt in Radical ComplianceResources to Assess ESG MaterialityTom in the FCPA Compliance and Ethics BlogThe Role of Compliance in ESGLeading the ESG Effort-Steps for ComplianceCompliance, Data Analytics and ESG Learn more about your ad choices. Visit megaphone.fm/adchoices

May 27, 2021 • 18min
Compliance Lessons from the Super League Fiasco
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 deep dive into the fiasco around the formation of the Super League in European Football (soccer), focusing on the role of John Henry, American owner of the Liverpool Football Club and the lessons for the (American) compliance professional. Some of the issues we consider are:
How do you make a cultural change?
Why it is mandatory to engage stakeholder in any discussions around cultural change?
What makes stakeholder want to follow a corp leader?
Why empathy is a mandatory leadership trait for any successful CEO.
Why understanding corporate subcultures outside the US is mandatory for the CCO.
ResourcesRead WSJ article Liverpool and the Red Sox Won on His Watch. For Fans, That’s Not Enough by Joshua Robinson Learn more about your ad choices. Visit megaphone.fm/adchoices

May 19, 2021 • 28min
Biden Administration Executive Order on Cybersecurity
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 deep dive into the Biden Administration’s recently released Executive Order on cybersecurity for both the federal government but also contractors who do work for the US government and their subcontractors. Some of the issues we consider are:
How will there be more and better sharing of threat information?
How will we achieve stronger cybersecurity within the government?
Why will contractors will need to have stronger oversight of their SW supply chain?
What will be the role of compliance?
What will be the role of internal audit?
ResourcesMatt’s blog post on Radical Compliance: Parsing Biden’s Cybersecurity Order Learn more about your ad choices. Visit megaphone.fm/adchoices

May 12, 2021 • 21min
Elon Musk, Cryptocurrency and the SEC
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 deep dive into the intersection of Elon Musk, cryptocurrencies and the SEC. Some of the issues we consider are:
What do make of Musk’s SLN performance?
What does the SEC have to say about all this?
What is the MicroStrategy, strategy?
What does the market think about all this?
Where is compliance?
ResourcesMatt’s blog post on Radical Compliance: Bitcoin We Have a Problem Learn more about your ad choices. Visit megaphone.fm/adchoices

May 5, 2021 • 23min
SAP Trade Sanctions Enforcement Action
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 deep dive into SAP trade sanction enforcement action. Some of the issues we consider are:
What were the underlying facts?
How did SAP allow products to get to Iran for so long?
How did SAP achieve a NPA even with aggrieved factors?
How was the financial penalty calculated?
What were the remedial steps SAP engaged in?
Why does this enforcement action point towards the need for a more holistic approach to risk?
ResourcesMatt’s blog post on Radical Compliance: SAP Nailed on Sanctions Violations Learn more about your ad choices. Visit megaphone.fm/adchoices


