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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, Tom Fox and Matt Kelly dive into the intricate and unusual story of the National Rifle Association (NRA) and its recent corporate governance overhaul.
Matt and Tom explore Judge Joel Cohen’s final ruling, which mandates extensive corporate governance reforms for the NRA. These reforms address significant issues, such as a structurally weak board, poor financial controls, and an overpowering CEO in Wayne LaPierre, who misused the organization’s resources. Necessary measures discussed include revamping the board’s audit committee and introducing annual compliance reports, along with significant protections for the role of the Chief Compliance Officer.
The episode highlights the universal principles of good governance, asserting that the NRA’s reforms can serve as a valuable lesson for other organizations. Regardless of the political or ethical stance on the NRA’s activities, the implemented governance structures underscore the necessity of transparency, an empowered compliance function, and robust oversight mechanisms to prevent misuse of organizational resources. These insights are illustrated through sample agreements and templates in the court ruling, which can guide other organizations in strengthening their governance and compliance programs.
Key highlights:
Corporate Governance Reforms Ordered by the Court
Specifics of the Court-Ordered Reforms
Audit Committee and Board Reforms
Compliance and Governance Templates
Universal Principles of Good Governance
Resources
Matt in 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 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, Tom Fox and Matt Kelly dive into a potpourri of issues, including Paul Atkins’s appointment to chair the SEC, a massaging of DOJ and the Corporate Enforcement Policy, and McKinsey’s FCPA resolution.
Tom and Matt discuss various compliance issues, focusing on the implications of Paul Atkins’ appointment as SEC chairman, the challenges of enforcement and corporate penalties, the role of whistleblowers, and recent FCPA enforcement actions, including the McKinsey settlement. They explore how Atkins’ conservative views may shape SEC policies and the potential impact on compliance officers and corporate governance.
Key highlights:
Paul Atkins and the SEC
Enforcement Challenges and Corporate Penalties
Whistleblower Protections and Compliance Officers
FCPA Enforcement and McKinsey Settlement
Resources:
Matt in 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 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, Tom Fox and Matt Kelly dive into the Trump Administration’s DOGE initiatives and what it might mean for compliance.
Tom and Matt discuss the implications of Elon Musk and Vivek Ramaswamy’s Department of Government Efficiency Committee (DOGE), which aims to downsize the federal government drastically. They explore the potential consequences of cutting half of all regulations and federal employees, particularly on compliance officers and corporate risk management. The conversation highlights how the reduction or abolition of federal regulations would affect various sectors, including the military, social security, and essential services, and delves into the challenges this proposal poses for compliance programs within businesses. They also consider possible outcomes such as increased state-level regulations, civil litigation, and the chaos and uncertainty that might follow. Finally, they discuss how companies should prepare for an inconsistent and unpredictable regulatory environment under a Trump administration.
Key highlights:
DOGE and Government Restructuring
Implications for Compliance Officers
Challenges of Cutting Regulations and Staff
Potential Consequences of Reduced Regulations and Non-Enforcement
Compliance Embedded in Business Practices
State-Level Regulation and Emerging Risks
Resources:
Matt in 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 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 Trump Administration’s DOJ nominees, FCPA enforcement going forward, and what it may all mean for compliance professionals.
Tom and Matt explore the potential impacts of these nominations, notably the controversial choice of Matt Gaetz as Attorney General, and how they could shape the direction of anti-corruption enforcement and compliance practices. They also discuss the realistic aspects of other nominees, including Trump’s attorneys Todd Blanche and Emil Bove and former SEC Chairman Jay Clayton, who proposed to lead the Southern District of New York. The conversation touches on potential strategies for compliance officers, such as the increased significance of self-disclosure and the broader ramifications for corporate and foreign policy enforcement under a Trump administration.
Key highlights:
Trump’s DOJ Nominees: An Overview
Potential Changes in FCPA Enforcement
Self-Disclosure and Compliance
Implications 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 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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