Changes in FCPA Enforcement

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. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Boeing’s recent safety initiatives and reforms, as outlined in their annual aerospace safety report. They explore Boeing’s efforts to improve its speak-up culture, internal reporting systems, and the introduction of an expansive Safety Champions Program. The episode explores the procedural changes Boeing has implemented, including the handling of third-party reports and increased transparency for employees. Additionally, they examine the challenges and necessities of manager training in fostering an ethical corporate culture. The conversation concludes with insights on the recent Federal District Court hearing regarding Boeing’s non-prosecution agreement and the implications for transparency and accountability. Key highlights: Speak Up Culture Enhancements Ambassador Program Expansion Manager Training and Corporate Culture Court Hearing on Boeing’s Non-Prosecution Agreement Resources: Matt Kelly 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. 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. Are you seeking insightful perspectives 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 COSO Corporate Governance Framework. Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework’s six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft. Key highlights: Overview of COSO’s Draft Corporate Governance Framework The Six Objectives of the Framework Importance of Culture in Compliance Principles and Points of Focus Resilience in Corporate Governance Resources: Matt Kelly 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. 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. Are you seeking insightful perspectives 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 recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump’s executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA 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. 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. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly consider what happens when AI turns whistleblower. The advent of AI technologies, such as Claude Opus 4, has sparked debates over the potential for AI systems to autonomously report misconduct, presenting new ethical and operational challenges within AI governance. Tom Fox views AI whistleblowing with caution, questioning the feasibility of implementing effective governance rules and the complexities involved in distinguishing between AI-generated reports and those of human whistleblowers. His concerns are shaped by the legal and ethical implications of AI’s autonomous actions, highlighting a pressing need for clearer regulations. Similarly, Matt Kelly is concerned about the ethical nuances, emphasizing the difficulty AI might face in understanding corporate ethics and compliance culture without human oversight, and underscores the urgent need for regulatory frameworks to keep pace with the advancements in AI. Fox and Kelly’s perspectives converge on the necessity for robust oversight mechanisms and strategic planning to manage the compliance challenges posed by AI in whistleblowing scenarios. Key highlights: Autonomous AI Reporting Misconduct to Authorities Navigating AI Ethics for Regulatory Compliance Distinguishing AI Reporting in Whistleblower Cases Navigating AI Challenges in Compliance Programs Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn 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 seeking insightful perspectives on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the Department of Justice’s recent proposal to grant Boeing a non-prosecution agreement. This decision stems from the 737 MAX crashes in the late 2010s that killed 346 people. They cover the history of Boeing’s settlements, the details and leniency of the new agreement, the role and scope of the independent compliance consultant, and the implications for corporate compliance and the victims’ families. The discussion highlights the potential end of compliance monitors and the broader impacts on corporate accountability. Key highlights: DOJ’s Non-Prosecution Agreement with Boeing Changes in the Settlement Agreement Role and Scope of the Independent Compliance Consultant Implications for Compliance Monitorships Boeing’s Whistleblower Program and Compliance Efforts Judicial and Victims’ Family Reactions Resources: 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. 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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this episode of Compliance into the Weeds, Tom Fox and Matt Kelly deeply dive into a recent tweet by President Donald Trump targeting Walmart and their announced intention to raise prices based on increased tariff costs. The discussion explores the implications of Trump’s demand that Walmart absorb tariff costs instead of passing them on to consumers. It examines the broader implications for stakeholder capitalism, the role of presidential influence on corporate governance, and the complexities of risk management in an unpredictable political climate. The episode also touches on ESG issues and the delicate balance companies must strike in navigating these challenges. Key highlights: Trump’s Tweet and Walmart’s Dilemma Stakeholder Capitalism vs. Shareholder Primacy Corporate Governance and Presidential Influence Legal Implications and Corporate Compensation Risk Management in Unpredictable Times Resources: 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, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. 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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this Compliance into the Weeds episode, Tom Fox and Matt Kelly deeply dive into the potential gift of a luxury Qatari jetliner to President Trump. We discuss the launch of Trump’s meme coins and the Qatari government’s allegedly planned $400 million plane donation to Trump. The conversation examines the compliance and corruption risks these actions pose for U.S. and international businesses. Kelly emphasizes how these incidents challenge ethical standards and underscore the importance for companies to address new forms of corruption proactively within their anti-corruption programs. Key highlights: Trump’s Alleged Corruption: An Overview The Meme Coins Controversy The Qatari Plane Donation Compliance and Integrity in the Face of Corruption 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, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. 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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the declination recently given by the DOJ to the Universities Space Research Association (USRA). In this episode, Tom and Matt dive deeply into a recent decline issued by the Department of Justice (DOJ) to the University Space Research Association (USRA). The discussion focuses on the organization’s exemplary behavior in self-disclosure and cooperation during an investigation into an employee’s misconduct. This misconduct included unauthorized export of software to Beijing University. The hosts highlight the case as a textbook example of effective compliance practices, self-reporting, and cooperation with regulators. They also explore the DOJ’s guidelines on self-disclosure and the importance of internal controls in high-risk areas. Key highlights: Case Overview: USRA Declination DOJ Press Release Insights Details of the Misconduct USRA’s Response and Cooperation Resources: DOJ Press Release on Universities Space Research Association Declination Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was 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. 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. Are you 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 take a deep dive into the settlement of charges by the OCC with two former top audit executives at Wells Fargo for their oversight failures during the bank’s fake accounts scandal. The Wells Fargo banking scandal is a cautionary tale of unchecked corporate misconduct and the critical role of auditor accountability. This scandal, which erupted due to Wells Fargo’s creation of fake accounts driven by unrealistic sales targets, exposed the bank’s dysfunctional corporate culture and raised questions about the efficacy of internal audits and the broader implications of regulatory actions. They discuss the scandal as emblematic of the broader issues stemming from repealing the Glass-Steagall Act, which blurs the lines between investment and consumer banking, fostering an environment where misconduct could thrive. Kelly points to the enormity of banks’ post-Glass-Steagall repeal as a breeding ground for potential misconduct and highlights the negligence of Wells Fargo’s leadership in failing to curb unethical practices. Both Fox and Kelly underscore the necessity for a comprehensive reevaluation of compliance and audit roles to prevent future scandals of this magnitude. Key highlights: Settlement of OCC Charges in Wells Fargo Impact of Regulatory Actions on Auditors Unethical Sales Goals Impacting Corporate Culture Glass Steagall Act Repeal: Wells Fargo Impact Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn 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. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the future role of compliance monitors in the corporate world under the Trump administration. Despite the potential for changes, federal prosecutors are expected to continue using compliance monitors as a critical tool. However, the criteria for assigning these monitors may become more limited. The episode critically examines the trustworthiness of statements from the Trump administration and its Justice Department, emphasizing the uncertainty facing corporations and compliance professionals moving forward. Key highlights: Trump Administration’s Stance on Monitors Criteria for Assigning Monitors Skepticism Towards Statements Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices