• Compliance into the Weeds

  • By: Tom Fox
  • Podcast

Compliance into the Weeds

By: Tom Fox
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  • Summary

  • 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.
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Episodes
  • The 2024 ECCP on Data Access

    The 2024 ECCP on Data Access
    Oct 2 2024
    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 Tom Fox and Matt Kelly take a deep dive into the 2024 update to the Department of Justice's guidelines for corporate compliance programs, focusing on data and data access. Tom and Matt explore the significance of these updates and whether they stem from companies showing advancements in data analytics or the DOJ recognizing gaps in data access for compliance officers. The discussion highlights the challenges compliance officers face, especially with diverse ERP systems and data silos, and provides insights into how compliance officers can leverage these guidelines to advocate for better data access within their organizations. The episode also breaks down specific questions from the DOJ’s guidelines, offering practical advice on addressing obstacles to data, resources for data access, and data maintenance. Key Highlights · The Importance of Data Access in Compliance · Challenges in Data Access for Compliance Officers · DOJ's Six Key Questions on Data Access · Addressing Data Access Impediments · Tools and Resources for Data Analytics · Communicating with the Board on Data Analytics Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
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    26 mins
  • Argentieri Speech and Updated ECCP – The First Analysis

    Argentieri Speech and Updated ECCP – The First Analysis
    Sep 25 2024
    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 Tom Fox and Matt Kelly take a deep dive into the speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ’s increased scrutiny on companies speak-up cultures and the protection of whistleblowers. Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs. Key Highlights · Key focus on enhancing whistleblower protections. · Compliance officers must ensure that reporting mechanisms are well-publicized. · Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training. · The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines. · The practical steps for compliance professionals to align their programs with DOJ’s evolving expectations. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
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    27 mins
  • Everything Old is New Again - The John Deere FCPA Enforcement Action

    Everything Old is New Again - The John Deere FCPA Enforcement Action
    Sep 18 2024
    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 Tom Fox and Matt Kelly take a deep dive into the recent Securities and Exchange Commission FCPA enforcement action involving John Deere. The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit. A critical issue was John Deere's delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to. Key Highlights · Details of the Bribery Scheme · Internal Control Violations · Pre and Post-Acquisition Due Diligence Issues · Remedial Steps and Improvements · Root Cause Analysis and Lessons Learned Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
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    22 mins
Management Economics Politics & Government
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