Episodit

  • 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  
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  • 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 SEC enforcement actions against several companies for pre-taliation clauses and related illegal intent.
     
    Our conversation discusses recent enforcement actions by the SEC sanctioned against seven companies for a total of $3 million in civil penalties. The main issue was that these contracts required employees to forfeit any right to whistleblower awards if they reported misconduct to regulators. The conversation explores the legality of these contract clauses and the chilling effect they have on potential whistleblowers. Tom and Matt also discuss the challenges of remediation and the need for a comprehensive approach to address retaliatory clauses in all types of contracts.
    Key Highlights

    SEC Enforcement Actions on Pre-Retaliation Language

    The Illegality of Pre-Retaliation Clauses

    Addressing Pre-Retaliation Clauses: Remediation Challenges

    Expanding the Focus: From Employment Contracts to All Contracts



    Resources
    Matt in Radical Compliance

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  • 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 Department of Justice (DOJ) declination for the Boston Consulting Group (BCG).
    They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations.

    Key Highlights:

    Overview of the Boston Consulting Group Declination

    DOJ’s Factors for Declination

    Full Cooperation, Timely Self-Disclosure and Employee Consequences

    Remediation Efforts and Compliance Improvements


    Resources:
    Matt in Radical Compliance
    Tom in the FCPA Compliance and Ethics Blog

    Tom  
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  • 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 question of whether a law degree is necessary for Chief Compliance Officers (CCOs). 

    Tom and Matt begin with a discussion of a recent compensation survey by Barker Gilmore that reveals CCOs with law degrees earn significantly more than their counterparts without JDs. They explore historical and practical reasons for this pay disparity and debate the actual necessity of a law degree for fulfilling modern compliance functions. Additionally, they identify key skills and functions essential for effective compliance and consider alternative career paths and educational backgrounds suited for aspiring compliance professionals.


    Key Highlights

    ·      The Value of a Law Degree for Compliance Officers
    ·      Breaking Down the Pay Disparity
    ·      Modern Compliance Demands
    ·      Career Paths and Skills for Compliance Officers

    Resources
    Matt in Radical Compliance
     
    Tom  
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  • 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 toxic workplace culture at Bank of America (BoA) around hours worked by junior employees, in spite of senior management saying the right things.
    BoA’s investment banking division has long been plagued by a toxic work culture, characterized by overworked junior employees and severe health crises, despite repeated assurances of reform. Tom Matt discuss these pervasive issues within BoA’s work environment. Fox highlights the tragic consequences of this toxic culture, such as the deaths of junior employees, and criticizes the company's failure to implement effective reforms, attributing this to a lack of accountability and ethical leadership. Kelly echoes this sentiment, emphasizing the necessity for senior management to set clear expectations and consequences for middle managers who perpetuate unethical behavior. Both stress the need for senior management to address the deep-seated cultural dysfunction, impose consequences, and foster a healthier, rule-abiding workplace to prevent further tragedies and promote employee well-being.

    Key Highlights:


    Toxic Workplace Culture at Bank of America

    Proactive Controls for Preventing Employee Overwork

    Consequences of Middle Managers in Corporate Culture

    Cultural Impact: Negative Attitudes in Organizations


    Resources:
    Matt in Radical Compliance

    How Bank of America Ignores Its Own Rules Meant to Prevent Dangerous Workloads, by Alexander Saeedy in the WSJ

     Tom
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  • 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 some of the nettlesome internal challenges faced by many Chief Compliance Officers (CCOs) in today’s corporate environment.

    On Compliance into the Weeds, Tom and Matt discuss the various challenges that CCOs face within organizations. They delve into stories of how senior management, particularly General Counsels (GCs) and Chief Financial Officers (CFOs), can sometimes undermine compliance efforts. The conversation explores issues such as budget cuts, restrictive vendor usage, structural impediments, passive-aggressive behaviors, and direct interference in investigations. They also consider potential solutions and strategies for CCOs to better navigate these struggles and ensure the effectiveness of compliance programs.

    Key Highlights:


    Budgetary Constraints and Sabotage

    Interference in Investigations

    Structural Impediments to Compliance

    Undermining by Engagement and Assignment

    Advice Going Forward


    Resources:

    Matt in Radical Compliance

    Tom  
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  • 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 recently announced Department of Justice (DOJ) Whistleblower Incentive Program.

    Last week, the DOJ announced a whistleblower pilot program, offering monetary rewards to whistleblowers who report corporate misconduct. Whistleblowers can receive up to 30% of the net proceeds of a settlement resulting from their tip. The program covers various types of corporate crime, including bribery, healthcare fraud, and Foreign Corrupt Practices Act (FCPA) violations.
    This program puts pressure on compliance programs to quickly investigate and address reported misconduct. It also raises questions about how whistleblowers will be rewarded in cases where there is a declination or non-prosecution agreement. The SEC case involving a whistleblower award highlights the importance of handling whistleblower reports effectively.

    Key Highlights:

    DOJ Announces Whistleblower Pilot Program

    Covering Various Types of Corporate Misconduct

    Tension Between Self-Reporting and Whistleblower Reporting

    Recent SEC whistleblower award as a cautionary tale


    Resources:
    Matt in Radical Compliance 
    Tom
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  • 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 Plea Agreement filed by the DOJ in the Boeing criminal case.

    Today we delve into the proposed plea agreement between the Department of Justice and Boeing, following violations of the company’s 2021 Deferred Prosecution Agreement (DPA). We discuss the detailed aspects of the plea, including a $243 million criminal penalty, a $455 million compliance investment plan, a three-year prosecutor probation with a compliance monitor, and a unique interaction between Boeing’s board and the families of crash victims.

    Matt and Tom also explore Boeing’s obligations to integrate safety and quality programs with its ethics and compliance initiatives, and the implications of these stringent new requirements.

    Key Highlights:

    Boeing’s Compliance and Safety Issues

    Expansion of Corporate Compliance Role

    Implications for Boeing’s Compliance Culture

    Monitor, Oversight, and Victim’s Families

    Role of the Board and Compliance Spending

    Future Considerations and CCO Certification


    Resources:

    Matt in Radical Compliance
    Tom in the FCPA Compliance and Ethics Blog

     Tom
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  • 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 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 dismissal of the SEC’s enforcement action against Solar Winds and CrowdStrike cybersecurity failures.
    Tom and Matt begin with UnitedHealth’s costly ransomware attack, a federal judge’s ruling against the SEC’s lawsuit over SolarWinds’ cybersecurity practices, and CrowdStrike’s flawed software update impacting global corporations.
    The episode explores the regulatory challenges of enforcing effective cybersecurity controls and the implications for companies and their compliance programs. The discussion highlights the need for better IT general controls and the role of different stakeholders, including Congress, regulatory agencies, and audit firms, in addressing these cybersecurity risks.

    Key Highlights:


    UnitedHealth Ransomware Attack Breakdown

    SolarWinds Cybersecurity Lawsuit

    Regulatory Challenges and Implications

    Operational Risk Management and IT Controls

    Call to Action for Compliance and Audit Professionals




    Resources:
    Matt on Radical Compliance
     
    Tom  
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  • 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 a recent SEC enforcement action involving RR Donnelley, where a cyber breach was characterized as an internal control

    In this episode, we discuss how criminal activities in cyberspace are outpacing regulatory measures and the law’s ability to keep up. The conversation touches on the idea that access controls for valuable corporate assets, whether financial data or sensitive information, are becoming indistinguishable in the eyes of cybercriminals. The discussion includes a thought-provoking perspective on merging cybersecurity and anti-money laundering functions, as both deal with improper electronic transactions. The core concern is not just the breach itself, but also the prevention of data exfiltration.


    Key Highlights:

    Corporate Jewels: Money vs. Data

    Cybersecurity and Anti-Money Laundering

    Improper Electronic Transactions

    Focus on Data Exfiltration

    Conclusion: Preventing Data Theft


    Resources:
    Matt on Radical Compliance
     
    Tom  
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  • 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 analyzing term-ending Supreme Court decisions from a compliance perspective. 

    They address the Jarkesy decision on SEC in-house tribunals, the Loper ruling overturning the Chevron deference doctrine, and the Snyder decision that narrows the scope of federal anti-corruption law. Despite the headlines, they conclude that these rulings have minimal direct impact on corporate compliance programs, emphasizing the ongoing importance of ethical integrity and effective compliance practices.

    Key Highlights

    ·      Supreme Court Cases Impacting Compliance
    ·      The Jarkesy Decision: Minimal Impact on Compliance
    ·      The Loper Case: Chevron Deference Overturned
    ·      The Snyder Decision: A Controversial Ruling
    ·      Implications and Final Thoughts


    Resources
    Matt on Radical Compliance
     

    Tom  
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  • 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 complexities surrounding the Department of Justice's potential decision to criminally prosecute Boeing under its Deferred Prosecution Agreement (DPA) related to the 737 MAX crashes. 
    They explore the various facets of corporate justice, including retribution, remediation, and societal interests, as well as the challenges in balancing justice for the victims and the broader implications for public safety and corporate culture. The discussion also covers the FAA’s role, the potential for new operational limits on Boeing, the impact and structure of compliance monitorships, and what compliance officers can learn from this high-stakes scenario.
    Key Highlights
    ·      DOJ and Boeing: The 737 MAX Dilemma
    ·      Corporate Justice: Individuals vs. Corporations
    ·      Balancing Justice and Corporate Interests
    ·      Deferred Prosecution Agreements: Compliance Challenges
    ·      07:33 Financial Penalties vs. Operational Limits
    ·      The Potential of Monitorships
    ·      FAA's Role and Challenges
    ·      Compliance Lessons and Future Considerations
    Resources
    Matt on Radical Compliance
     Tom  
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  • 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 delve into the recent speech by Michael Hsu, the head of the Office of the Comptroller of the Currency, on the accountability challenges posed by artificial intelligence in the banking sector. 
    The discussion highlights Hsu's emphasis on the lack of a robust accountability framework for AI, illustrating the issue with the Air Canada chatbot incident. The conversation also touches on potential systemic risks AI could pose to the financial sector, the need for explainable AI, and the shared responsibility model used in cloud computing as a potential template for addressing these challenges. The episode underscores the necessity for compliance officers to ensure contracts and IT controls are in place and stresses the importance of developing trust and accountability mechanisms before widespread AI adoption.
    Key Highlights
    ·      AI Accountability: A Regulator's Perspective
    ·      Case Study: Air Canada's AI Mishap
    ·      Legal and Technological Challenges
    ·      Exploring Solutions and Shared Responsibility
    Resources
    Matt on Radical Compliance
     Tom  
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  • 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 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 and Matt take a deep dive into last week’s trial verdict against Donald Trump in NYC and lessons for the compliance professional.
    We explore the importance of internal controls, consistent consequence management, and effective leadership. They also delve into how compliance officers can learn from the storytelling strategies used in the trial and emphasize the application of the rule of law.
    Key Highlights:

    Overview of Trump’s Criminal Conviction

    Internal Controls and Compliance Lessons

    Consequences Management and Consistent Enforcement

    Ethical Leadership and Communication

    Who is your audience? Storytelling in Compliance

    Final Thoughts and Rule of Law


    Resources:
    Matt on Radical Compliance
     Tom  
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  • 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 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 and Matt delve deep into Citigroup’s $126 million trading error, resulting from poor internal controls.
    They discuss how a simple ‘fat finger’ error by a trader led to a major flash crash on European stock exchanges in 2022, and how the failure of Citigroup’s internal controls allowed it to happen. The discussion covers multiple compliance lessons, including the importance of understanding the human element in control design, the need for adequate staffing and monitoring, and the necessity of consistent global risk management.
    Fox and Kelly also highlight the importance of addressing findings from internal audits and maintaining urgency in improving internal controls. They emphasize that companies should think creatively about risk management, taking into account various global factors, including holidays and local regulations.

    Key Highlights:

    The Citigroup Internal Control Fiasco

    Compliance Lessons from Citigroup's Mistake

    The Human Element in Compliance and Control Failures

    Global Consistency in Risk Management

    Resources:
    Matt on Radical Compliance
     Tom  
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  • 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 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 a recent report by Prevalent on Third Party Risk Management in 2024 and Microsoft’s 2024 Environmental Sustainability Report.
    Tom and Matt discuss the challenge companies face in aligning their sustainability goals with their supply chain management. They question whether sustainability functions within a company have the authority to influence supply chain decisions, such as rejecting suppliers that do not meet sustainability criteria.
    We discuss the  Microsoft Report, noting that while the company acknowledges it has not yet achieved the ability to reject non-compliant suppliers, it suggests a target of improvement by 2030. The core issue highlighted is whether sustainability initiatives will have significant influence over supply chain decisions in the future. 

    Key Highlights:

    Intersection of Supply Chain Risk Management and Sustainability

    The Role of Sustainability in Supply Chain Decisions

    Microsoft’s Journey Towards Sustainable Supply Chain Management

    The Energy Industry Model


    Resources:
    Matt on Radical Compliance
    Tom  
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  • 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 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 and Matt look at the absolutely scathing report issued by the law firm Cleary Gottlieb on the toxic culture of harassment and abuse at the Federal Deposit Insurance Corporation.
    A recent scandal has been unveiled in the U.S. banking sector, spotlighting the Federal Deposit Insurance Corporation (FDIC). A report has unveiled a toxic corporate culture riddled with instances of harassment, whistleblower retaliation, and poor leadership under Chairman Martin Gruenberg.
    Fox, viewing the scandal as a pivotal moment, emphasizes the need for accountability and radical change within the organization, particularly in addressing the issues revealed in the report. Despite the daunting challenges, Fox maintains a level of optimism, believing that with the right management and leadership changes, the FDIC can rectify its corporate culture.
    Kelly recognizes the deep-seated cultural issues brought to light by the report, nonetheless, he believes that due to the FDIC's relatively small size, with the right leadership and cultural shifts, it is possible to turn the organization around. Both experts' perspectives are rooted in their understanding of corporate culture and governance, and their beliefs in the power of effective leadership and cultural change.

    Key Highlights:

    Toxic Culture Exposed in FDIC Report

    Ethical Culture Assessment in Banking Regulation Systems

    Toxic Culture: Mismanagement & Whistleblower Retaliation

    Structure and Toxic Corporate Environment

    Transformative Potential within the FDIC


    Resources:
    Matt Kelly on Radical Compliance
    Tom 
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  • 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 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 look into an absolutely wacko SEC enforcement action involving BF Borgers and its founder and principal, Benjamin Borger’s.
    The auditing sector was recently rocked by the Securities and Exchange Commission’s (SEC) investigation into BF Borgers CPA, an auditing firm with over 1,600 problematic disclosures. The incident, which serves as a reminder of the critical role played by audit committees in ensuring appropriate audit procedures,.
    Only a fraudster can admire the audacity of Benjamin F. Borgers in fabricating audit reports for hundreds of clients, which underscores the need for enhanced governance and regulatory measures to prevent similar incidents in the future.
    We discuss the impact on smaller public companies, focusing on their struggles to find competent and affordable audit firms. Matt raised the question of where the company’s audit committees were during all this fraudulent work. He also speculates on potential legal repercussions for Borgers and his firm. Both perspectives highlight the gravity of the situation, the need for improved oversight, and potential consequences of such actions.
    Key Highlights:

    Audit Quality Oversight in Regulatory Environment

    Finding New Auditors After Losing Previous Firm

    Limited Options for Small Company Auditors

    Proactive Monitoring of Audit Firms by Committees


    Resources:
    Matt on Radical Compliance
     Tom  
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  • 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 and Matt look into corporate reports on their Boards’ oversight of AI. 
    As the world ventures deeper into the age of artificial intelligence (AI), the issue of corporate governance over AI is emerging as a crucial point of discussion. Tech giants such as Google are facing demands for more board-level attention to AI risk management due to concerns about the lack of transparency and oversight. Tom highlights this lack of detailed consideration of AI at the board level, raising doubts about whether boards are suitably prepared for AI's rapid development and potential enforcement risks. His concerns are rooted in limited mentions of AI in proxy statements of S&P 500 companies, suggesting current practices might not be sufficient for the future. 
    Meanwhile, Matt emphasizes the need for boards to start considering staffing, expertise, and risk management related to AI without necessarily forming dedicated AI committees at present. Kelly's concerns stem from the lack of detail in proxy statements about what boards are currently doing with AI, especially in tech-heavy companies like Google, indicating the need for potential formation of dedicated committees or sub-specializations in the future.
     Key Highlights
    ·      AI Risk Management: Tech vs. Non-Tech Perspectives
    ·      Enhancing Corporate Governance Through AI Oversight
    ·      Technology Risk Oversight in Evolving Companies
    ·      AI Oversight for Corporate Boards: Future Risks
    Resources
    Matt on Radical Compliance
     Tom  
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  • 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 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 and Matt take a deep dive into imbroglio involving Jontay Porter and gambling on NBA games.
    The recent scandal involving the lifetime suspension of Jontay Porter from the NBA due to questionable prop bets, has sent shockwaves through the sports betting industry.
    Tom views this incident as a stark warning for compliance professionals, underscoring the importance of data analytics in detecting anomalies and misconduct. He notes that thorough data analysis can expose even lesser-known players like Porter to inappropriate behavior while also commending the NBA’s swift and decisive action to preserve the integrity of the game.
    Matt, a digital transformation advocate in sports betting, believes the scandal highlights the benefits of digital transformation in the industry. He stresses the crucial role of data analytics in identifying suspicious activity and potential misconduct, agreeing with the NBA’s decision to suspend Porter and protect the sport’s integrity.
    Both Fox and Kelly’s perspectives are shaped by their backgrounds in compliance and digital transformation, respectively, emphasizing the profound impact of data analytics in these areas.

    Key Highlights:

    NBA Suspension: Data Analytics in Sports Betting

    Sports Betting Fraud Prevention through Digital Transformation

    Unveiling Unusual Patterns in Financial Transactions

    Location-Based Anomalies in Investigative Analytics

    Consequence Management


    Resources:
    Tom on the FCPA Compliance Report
    Tom  
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