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 issue of compliance and artificial intelligence. Some of the issues we consider are: What are the AI risks for compliance? What guidance does the COSO Framework provide? What are some of the top areas of AI failure? Are we governing AI in the right manner? What about the audit of AI tools? Compliance, governance, ethics and AI.  Resources Matt in Radical Compliance Thoughts on AI From the Audit Perspective Grappling With Artificial Intelligence  Tom in the FCPA Compliance and Ethics Blog Compliance Communications: Using an AI Marketing Strategy – Part 1 Compliance Communications: Using an AI Marketing Strategy – Part 2 Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds

Compliance and AI

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 recent speech by SEC Director of Enforcement Gurbir Grewal and the likely increase in a more expansive use of SEC enforcement. Some of the issues we consider are: What is the purpose of SEC penalties; to penalize or to deter others? How did SEC Commissioner Crenshaw presage this talk? What about a potential change in DOJ penalties? Its approach and focus? Are monitorships back on the table? What about the CFPB? Will Directors and Officers be held accountable or just the low level minions?  Resources Matt in Radical Compliance More on SEC Penalties Policy Shift Learn more about your ad choices. Visit megaphone.fm/adchoices

Expansive SEC Enforcement in the Wind

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 collapse (and perhaps rebirth) of Ozy Media and have our first round of culture failure bingo.  Some of the issues we consider are: What is an Ozy and why does its collapse matter to compliance? Who is Ozzie Osbourne and what does he have to do with Ozy? What is culture failure bingo and why is it on Compliance into the Weeds? Who were the bingo winning companies this week? Why all this matter to compliance? Resources Matt in Radical Compliance  Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices

Ozy Media and Culture Failure Bingo

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 second FCPA enforcement action of 2021, involving the UK entity, WPP. Some of the issues we consider are: Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture? What is the role of compliance in M&A? When does a financial incentive become perverse? Where is the DOJ? Where is the SFO? How did WPP avoid a monitor?  Resources Matt in Radical Compliance WPP Pays $19M on FCPA: An Analysis  Tom in the FCPA Compliance and Ethics Blog Part 1-Background Part 2-Structural Compliance Deficiencies Part 3-Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices

The WPP Foreign Corrupt Practices Act 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 a recent survey around employee attitudes towards employer vaccination policies and enforcement of those policies.   Some of the issues we consider are: ·      What are employee attitudes toward employer vaccination policies? ·      Why is there a split between White Collar response v. Blue Collar responses? ·      What will be government enforcement?  ·      Will there be increased whistleblower reporting? ·      What could be the social media impact on corporate reputations?  Resources Matt in Radical Compliance Poll: 46% Would Report Lax Vax Policies Learn more about your ad choices. Visit megaphone.fm/adchoices

Lax Anti-Vax Policies

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 why an internal reporting system is not enough. Indeed having a speak up culture is not enough. Your company must have a listen up culture.   Some of the issues we consider are: ·      What is a speak up culture? ·      What is a listen up culture? ·      What are some of the benefits of a true listen up culture?  ·      How do you training middle managers to be speak up portals? ·      Why is having a conversation so powerful?  Resources Matt in Radical Compliance Corporate Culture: Speak Up v. Listen Up Learn more about your ad choices. Visit megaphone.fm/adchoices

Listening is a Conversation

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 the recent SEC enforcement action involving Kraft Foods. While the subject matter of the enforcement action was fraudulent expense recognition, it turns out the real culprit was a corrupt culture. Some of the issues we consider are: ·      What were the underlying facts? ·      What does tone at the top really mean? ·      How does management cost cutting mantra lead to corruption?  ·      Why is incentive based comp so deterius? ·      What did SEC Commissioner Crenshaw say about this enforcement action? Resources Matt in Radical Compliance Food For Thought From Kraft Foods Learn more about your ad choices. Visit megaphone.fm/adchoices

High Calorie Compliance Lessons from Kraft Foods

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 the recent move by Delta Airlines to require employees who refuse to be vaccinated to pay a special health care insurance surcharge of $200 to cover the increased health care costs associated with unvaccinated employees who contract Covid-19.  Some of the issues we consider are: ·      What were the underlying facts? ·      How did Delta Airline’s actions follow a risk management protocol? ·      How did Delta’s actions demonstrate a commitment to compliance?  ·      How about the data? ·      How about Document Document Document?  Resources Matt in Radical Compliance Delta’s Smart Approach on Delta Learn more about your ad choices. Visit megaphone.fm/adchoices

Delta Airlines Responds to the Delta Variant

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 announcement by Walmart that former DOJ Deputy Attorney General, Criminal Matthew Miner had joined the company as CCO.   Resources Matt in Radical Compliance Walmart Names ex-DOJ Boss CCO Learn more about your ad choices. Visit megaphone.fm/adchoices

Matt Miner Makes 3-Point Pivot into the Walmart CCO Chair

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 enforcement involving Pearson. Some of the issues we consider are: How can a failure to disclose lead to a SEC violation? What were the disclosure controls and procedures failures? How is patch management a critical part of cybersecurity? What were the misleading statements made by Pearson? What are the lessons learned? What is the role of compliance?  Resources Matt in Radical Compliance SEC Schools Pearson on Cyber Disclosure Failures Learn more about your ad choices. Visit megaphone.fm/adchoices

Pearson SEC 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 Venn Diagrams to consider the questions of who sets corporate values. Some of the issues we consider are: What happens when management dictates a corp value? What happens when that value is disputed by employees? What happens when the regulators come knocking? How does social media play into all this? How can you assess your risk? What is the role of compliance? Resources Matt in Radical Compliance Mapping the Pressures on Corporate Values, Priorities Learn more about your ad choices. Visit megaphone.fm/adchoices

Who Controls Corporate Values?

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 actions of Activision CCO Frances Townsend who when faced with a claim by the state of California of sexual harassment by the company in the workplace, went off the deep end. Some of the issues we consider are: ·      What happens when a CCO attacks internal whistleblowers? ·      How is the role of the CCO different from that of the GC?? ·      What happens when a company starts attacking its own employees?  ·      What happens when a CCO closes their door to employees? ·      The over/under on Townsend’s continued employment.   Resources Matt in Radical Compliance More Activison CCO Drama Activision CCO Steps Into a Mess Learn more about your ad choices. Visit megaphone.fm/adchoices

What Happens When a CCO Goes off the Deep End?

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 Deferred Prosecution Agreement entered into by First Energy company for its bribery of certain state officials in the state of Ohio, including the former Speaker of the House in Ohio. Some of the issues we consider are: What were the underlying facts? What were the bribery schemes involved? How did the tax code facilitate the bribery? What are the compliance program implications? How does this fit into ESG?  Resources Matt in Radical Compliance First Energy and Domestic Corruption Woes Learn more about your ad choices. Visit megaphone.fm/adchoices

First Energy Corruption Settlement

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent SEC enforcement action regarding the SPAC Stable Road Acquisition Corp. and its acquisition of the space technology company Momentus.  Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance due diligence? Bill Ackerman, Pershing Square Tontine Holdings and the proposed Universal Music acquisition? Diamond Acquisition Corp and its acquisition of Lordstown Motors.  Resources Matt in Radical Compliance The Second Act of SPAC Enforcement Learn more about your ad choices. Visit megaphone.fm/adchoices

SEC-SPAC 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 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?  Resources Matt in Radical Compliance Lessons from Robinhood Learn more about your ad choices. Visit megaphone.fm/adchoices

FINRA Enforcement Actions involving Robinhood

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. 