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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 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 dive into the recently released FCPA enforcement action involving the Telefónica Venezolana subsidiary.
They explore the bribery scheme used by Telefónica Venezolana to win an auction for U.S. dollars in 2014, resulting in a significant criminal penalty. The episode delves into the complexities of compliance in high-risk jurisdictions, the importance of incorporating anti-corruption due diligence into supply chains, and the implications of the new enforcement landscape under different administrations. Key lessons include the surprising extent of supplier risk, the long tail of FCPA enforcement, and the financial benefits of robust compliance practices.
Key highlights:
Details of the Bribery Scheme
Consequences and Penalties for Telefónica Venezolana
Compliance Challenges and Lessons Learned
Risk Management in High-Risk Jurisdictions
The Importance of a Robust Compliance Program
Long-Term Implications of FCPA Violations
Future of FCPA Enforcement
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 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 special election day episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into a lighter yet insightful compliance story involving a young boy named Danny Doherty.
At 12 years old, Danny set up a homemade ice cream stand in Massachusetts to raise money for a hockey team for children with developmental disabilities. However, the local health department shut its stand down due to risks associated with homemade dairy products, highlighting the importance of a risk-based approach in compliance activities. Tom and Matt discuss key compliance lessons from this incident, such as the necessity of addressing real risks, the potential for compliance failures despite good intentions, and the importance of effective communication by regulators.
Key highlights:
The Story of Danny Doherty
Compliance Lessons from Danny’s Story
Risk-Based Approach in Compliance
The Importance of Communication in Compliance
Resources:
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 the recent events at the Washington Post, where the newspaper decided not to endorse a presidential candidate for the first time in years.
This decision, directed by owner Jeff Bezos, has led to significant backlash, including 200,000 lost subscribers and concerns about the paper’s principles. Matt and Tom discuss the implications of this move on leadership, company values, and stakeholder trust, providing insights into the governance structure of newspapers and the potential fallout of abandoning established principles. We also turn to company values and if you are going to violate them, there should be sufficient justification. Finally, what a second Trump Administration might mean for corporate compliance.
Key Highlights:
Washington Post’s Controversial Decision
Newspaper Governance Explained
Washington Post’s Mission and Principles
Leadership Failures and Consequences
Potential Future Implications
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 RTX Foreign Corrupt Practices Act enforcement action.
Their discussion unveils complex bribery schemes involving millions paid to Qatari agents and the family of the Emir to secure defense contracts. Despite strict regulatory oversight, Raytheon’s (now RTX) compliance missteps spanned from 2012 into the 2020s, resulting in massive fines. Matt and Tom scrutinize these failures, detailing the SEC and DOJ’s mandates for dual monitorships due to violations of the False Claims Act and FCPA and the Board’s critical role in addressing these issues. Additionally, a comparative look at other significant FCPA cases, including Moog’s penalties for bribery in India, highlights persistent corporate misconduct and the ongoing challenges in achieving effective corporate compliance.
Key Highlights:
Overview of Raytheon’s Violations
Qatari Agent and Further Corruption
Raytheon’s Compliance Failures
Management and Compliance Failures
Board Oversight and Responsibilities
Reflections on Compliance and Enforcement
Resources
1. Blogs
Matt in Radical Compliance
2. 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 TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties.
In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank’s compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank’s strategy is a clear warning when a business puts profits over compliance.
Key Highlights
· Introduction to the Flat Cost Paradigm
· Details of the Budget Strategy
· Impact on Anti-Money Laundering Efforts
· Financial Growth Amidst Budget Constraints
Resources
1. Blogs
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
2. Tom
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3. Enforcement Related Material
A. OCC
OCC Press Release
Consent Order
Civil Money Penalty
B. DOJ
TD Bank US Holding Company Information
TD Bank N.A. Information
TD Bank US Holding Company Plea Agreement and Attachments
TD Bank N.A. Plea Agreement and Attachments
Merrick Garland Remarks
Nicole Argentieri Remarks
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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 study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance.
The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success.
Key Highlights:
Overview of the Compliance Study
Key Findings and Statistics
Challenges in Compliance Testing
Importance of Multiple KPIs
Access to Data Issues
Resources:
Matt in Radical Compliance
2024 Benchmarking Study: Testing & Monitoring and Data & Systems
Rethink 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 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
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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 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
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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 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
Tom
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Check out the full 3-book series, The Compliance Kids on Amazon.com.
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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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