Live from the Floor of ACI

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 of Compliance into the Weeds, Tom Fox and Matt Kelly look at the mixed and muddled messages coming out of the DOJ on FCPA and white collar enforcement.    We discuss recent signals from the DOJ suggesting a reinvigorated stance on corporate malfeasance, juxtaposed with actions like the pardoning of convicted offenders which muddle the overall message. The conversation covers Deputy Attorney General Todd Blanche's inflammatory speech on the seriousness of FCPA actions, the controversial pardons by President Trump, and the apparent selective enforcement against foreign versus U.S. companies. The episode examines the ramifications of these mixed signals for compliance professionals, companies, and whistleblowers, emphasizing the need for clearer guidance and consistency from the DOJ.  Key Highlights  ·      Mixed Messages from the Justice Department on FCPA and White Collar Enforcement ·      Deputy Attorney General's Angry Speech ·      Controversial Pardons and Their Implications ·      ZTE and FCPA Charges ·      Inconsistencies and Compliance Challenges ·      The Impact of Presidential Pardons on Compliance  Resources Matt 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 a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  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 it more fully. 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 discuss their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference. Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ’s focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severin Wirz’s new book, Bribery Beyond Borders, on the historical context of FCPA enforcement. Key highlights: FCPA Enforcement Realities White Collar Crime and DOJ Priorities Cartels and Corruption Whistleblower Program Insights Book Signing and Historical Context Resources: Matt 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. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. 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 it more fully. 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 discuss the recently released Serious Fraud Office (SFO) guidance on compliance programs. Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances. Key highlights: Introduction to SFO Guidance Comparing SFO Guidance with US Standards Uncertainty in SFO's Expectations Holistic Assessment by SFO Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog 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. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. 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 episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the intricate details of a recent FCPA  enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala. The discussion uncovers how Millicom's joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ’s earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom's operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions. Key highlights: Details of the FCPA Enforcement Action Millicom’s Joint Venture in Guatemala Self-Disclosure and DOJ’s Response Timeline of Events and Corruption Details Drug Trafficking and Bribery Connections Implications and Compliance Lessons Resources: Matt 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. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. 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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action.  The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity.  Key Highlights  ·      Lessons from Atlanta Hawks Fraud Case ·      Least Privilege Access for Preventing Financial Fraud ·      Financial Data Examination for Fraud Detection ·      Executives' Lavish Misconduct: Lessons in Ethics  Resources Matt 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 a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  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. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the intricacies of integrating incentives into corporate compliance programs. Matt shares insights from a recent webinar and blog posts, discussing how companies can encourage ethical behavior through executive compensation plans, performance bonuses, and other incentive schemes. The conversation explores the Justice Department’s guidelines on executive compensation, the intricacies of designing these programs to align with industry-specific risks, and the implications for various levels of management. They also examine the challenges of establishing meaningful compliance metrics and striking a balance between compliance incentives and overall business objectives across multiple sectors. Key highlights: The Role of Incentives in Compliance Programs Structuring Executive Compensation for Compliance Challenges and Nuances in Incentive Programs Incentives for Different Business Models Compensation Types and Ethical Behavior Resources: Matt 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. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award, all for excellence in podcasting. 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 it more fully. 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 discuss the unfolding NBA betting scandal and explore what it all might mean for the compliance professional.  Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals.  Key highlights: NBA Betting Scandal Overview Historical Context and Data Analytics Conflict of Interest and Risk Assessment Investigation and Compliance Strategies  Resources: Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠ 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. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.  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 episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the rare occurrence of a company, Smartmatic, being added to an existing indictment for FCPA violations. They explore the unusual circumstances surrounding this case, including the political sensitivity of Smartmatic, its ongoing litigation with Fox News, and the potential implications for corporate voluntary self-disclosure under the current administration. They delve into the changes in DOJ criteria for FCPA prosecutions and raise concerns about selective prosecution and the broader impact on compliance strategies. Key highlights: Overview of Smart Medic Indictment Political Context and Conspiracy Theories Implications for Compliance and Self-Disclosure Concerns About Selective Prosecution 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, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence. 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 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 discuss Matt’s recent experience at a compliance conference in Lithuania and engage in a thorough discussion about effective human oversight in AI systems. They examine the recent guidance from the European Data Protection Supervisor (EDPS) on maintaining human oversight of automated decision-making processes, relating it to similar regulatory requirements in California. The conversation explores the implications for corporate compliance, IT, and audit professionals, highlighting the challenge of balancing AI efficiency with the need for effective human intervention to mitigate risks and ensure regulatory compliance. Key highlights: Matt’s Experience in Lithuania AI Regulation in the EU and CCPA Amendments re: ADS and ADMT Effective Human Oversight in AI Systems Challenges in AI Control Design The Role of Compliance and Audit in AI Oversight Resources: Matt on Radical Compliance Tom with a 5-Part podcast series on the CCPA Amendments on ADS/ADMT with Alyssa DeSimone on Life with GDPR 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. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. 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 episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the implications of artificial intelligence, specifically the use of chatbots in compliance programs. Matt joins from Vilnius, Lithuania, where he is set to address a gathering of Baltic and Eastern European compliance professionals. The discussion centers on AI chatbots used for policy guidance, specifically addressing the ethical concerns and potential risks associated with tracking individual employee inquiries, as well as the possibility of violating whistleblower protection laws. Tom and Matt emphasize the importance of robust IT general controls and corporate culture in managing these new AI-powered compliance tools. They also address how regulators, like the Department of Justice, may evaluate the effectiveness of AI in compliance programs going forward. Key highlights: Exploring AI in Compliance Chatbot Concerns and Whistleblower Anonymity User Experience vs. Compliance Function Experience Regulatory Expectations and Future of AI in Compliance Resources: Matt on 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. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices