Compliance into the Weeds
- Episódios
- 452
- Publicação
- semanal
- Último episódio
- 11 nov 2026
Sobre o podcast
What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance.
Episódios 452
Mapping and Managing AI Agents’ Compliance Risk
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for some …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this special episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a Darrow AI report on whether leading LLMs can build privacy-sensitive websites while recognizing compliance obligations.
Darrow had seven “frontier” models build three hypothetical sites involving personal data (pediatric lab results, credit scores, and mental health services) and scored them against a privacy/compliance checklist. With no compliance prompting, models averaged about 28/100; with generic privacy prompts, about 63.5; and with extensive documentation and technical specifications, about 88.6 (the top model around 95), with none reaching 100. They highlight “ghost controls,” where front-end compliance features (e.g., opt-out buttons) lack back-end functionality. The conversation stresses that prompting quality, technical specifications, and clear human oversight are essential, especially amid layoffs and “vibe coding,” and warns that GDPR/CCPA risks scale with AI speed. They note insurers requested the research and may push governance requirements.
Key highlights:
- Darrow Study Setup
- Workplace Oversight Risks
- Ghost Controls Explained
- Governance at Scale
- Beyond Websites to Projects
- Insurance Pressure Coming
Resources:
Tom
A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.
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Emergency Podcast on Election Results
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for hard-hitting …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds!
In this special episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the 2026 election results and what they may mean for compliance.
Key highlights:
- Corruption investigations in Washington
- Anti-corruption legislation and enforcement
- AI regulation and Data Center moratoriums
- Administration Staffing
- State AGs and Business Courts in Texas
- Prediction Markets
- Supreme Court
Resources:
Tom
A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.
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Extreme Networks: The “Imminent Threat” Limit on Voluntary Self-Disclosure Credit
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ and OFAC actions involving Extreme Networks.
The company’s Russia office sold advanced networking equipment to Avangard, a Russian state-owned defense firm on U.S. sanctions lists via majority ownership by Almaz-Antey. After a whistleblower report in April 2022, Extreme investigated and briefed its board by June but did not disclose until investigative reporters contacted the company in October with additional facts, prompting a renewed inquiry and self-disclosure by year-end. DOJ deemed the disclosure driven by an “imminent threat,” denied voluntary self-disclosure credit, and issued a non-prosecution agreement rather than a declination, with $2.5 million in combined penalties. The episode examines uncertainty about what changed, how DOJ benefits from quality disclosures, and OFAC’s emphasis on timely, effective screening and heightened diligence in high-risk jurisdictions like Russia.
Key highlights:
- The enforcement actions
- Imminent Threat Debate
- OFAC Red Flags
- Screening Lessons
- Self Disclosure Policy
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.
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Anthropic’s Board Structure - What Does it Mean for Compliance
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 it fully. Looking for hard-hitting …
Notas do episódio
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 it fully. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Anthropic’s S-1 registration statement for a forthcoming IPO, focusing on what it reveals about corporate governance and risk oversight rather than financials.
Kelly notes Anthropic has a seven-member board with three insiders (CEO Dario Amodei, Daniela Amodei, and CFO Christina Rao) and four outsiders, operating through four committees: audit, compensation, nominating/governance, and a safety and risk committee tasked with AI safety, security, and broader legal/regulatory/compliance risks. They question whether a two-member safety and risk committee, chaired by Novartis CEO Vas Narasimhan and joined by Christopher Liddell, has sufficient capacity, and note that the committee has an undisclosed written charter. They also flag uncertainties about Anthropic’s internal compliance/risk leadership and reporting filters, potential amended filings, and a five-member long-term benefit trust (one seat vacant) with influence over nominating outside directors.
Key highlights:
- Anthropic IPO S-1 overview
- Board size and committees
- Risk committee staffing questions
- CEOs talking about AI risks
- More filings and disclosure gaps
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.
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Bank of America’s $1.2B AML Breakdown: Too Big to Remediate?
The award-winning Compliance into the Weeds is the only weekly podcast that dives deep into compliance-related topics, going into the weeds to uncover hard-hitting compliance insights. Look no further than …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that dives deep into compliance-related topics, going into the weeds to uncover hard-hitting compliance insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against BAO for $1.2bn.
The enforcement action against Bank of America (with OCC, FinCEN, OFAC, and others) was for BOA’s failure to maintain an effective Bank Secrecy Act/AML program, including flawed transaction monitoring that led to inadequate suspicious activity reporting, weak customer due diligence, and deficient sanctions screening, sometimes with law enforcement flagging issues to the bank rather than the reverse.
They place this alongside recent actions against UBS, American Express, and a New York DFS fine of SEB, arguing recurring failures stem from poor transaction analysis. Kelly ties Bank of America’s problems to its homegrown “Event Processor” system, launched in 2010, which critics say uses arbitrary risk-scoring thresholds and lacks recalibration, compounded by insufficient staffing and management support. They highlight governance and accountability concerns, including unresolved findings from a 2024 OCC order, questions about board oversight of compliance, and doubts that fines alone will drive lasting remediation.
Key highlights:
- BofA Fine Breakdown
- What Went Wrong in AML
- How the Tech Failed
- Leadership and Culture Accountability
- Fixing It People and Oversight
- Risk Assessments and Too Big to Remediate
Resources:
Matt in Radical Compliance
Tom in the FCPA Compliance Report
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.
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Amex AML Enforcement: Credit Card Risk, SAR Failures, and Board Accountability
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance topics, literally going into the weeds. Looking for hard-hitting compliance insights? Look no …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance topics, literally going into the weeds. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against American Express.
The penalties included a $350 million civil penalty, cease-and-desist orders, and extensive compliance obligations tied to weaknesses in customer due diligence, suspicious activity reporting, staffing, and risk assessment. Tom highlighted that Amex processed billions of transactions, many ordinary credit-card transactions, showing banks must know all customers, not just high-dollar activity, and noted regulators’ broader pattern of similar actions across the industry as financial innovation outpaced compliance investment.
Matt noted that regulators depend on SARs as critical inputs for broader enforcement “mosaics,” explaining why SAR failures draw intense scrutiny. The orders’ notable feature is direct board involvement, requiring a board-level compliance committee and action plan to hold management accountable, with a strong focus on end-to-end documentation and evidence trails; they see no facts suggesting the egregious, employee-involved criminality seen in TD Bank.
Key highlights:
- Industry Pattern and Root Causes
- Innovation as Compliance Risk
- Board Oversight Mandates
- Why SARs Matter
- DOJ Risk and TD Bank Comparison
- Disjointed Compliance and Fixes
Resources:
Tom in the FCPA Compliance Report, Part 1 and Part 2
Tom
A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.
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New Fraud Section Guidelines
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for hard-hitting …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ’s new Fraud Division enforcement priorities.
The DOJ’s Fraud Division enforcement priorities matter because they can quickly reshape a company’s compliance risk, especially when prosecutors are told to focus on patterns like widespread victimization, large losses, senior management involvement, and obstruction of investigations. Tom argues updates are a practical cue for compliance leaders to reopen discussions with senior management, the audit committee, and the board, while also treating whistleblower incentives and even political risk as real factors on the company risk register. Matt similarly argues that the DOJ’s new posture has changed enforcement risk and that companies should respond by refreshing risk assessments, sharpening internal controls, and briefing leadership before problems become more costly. Both perspectives are shaped by their long experience covering corporate compliance and enforcement, with Fox emphasizing proactive governance and Kelly stressing the need to translate DOJ signals into concrete, business-specific risk management.
Key highlights:
- 10-Factor Fraud Prosecution Memo for Corporations
- Multiple Small Fraud Indicators, Material Weakness Risk
- DOJ Shift Raises Compliance Costs and Stakes
- Declinations for Companies That Voluntarily Self-Disclose
- Corporate Enforcement Section and 2024 ECCP
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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Southern Glazer’s NPA: How Remediation and ECCP Alignment Drove a Favorable Settlement
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Southern Glazer NPA.
The Southern Glazer Wine and Spirits’ non-prosecution agreement is a rare example where prosecutors credited compliance program remediation, rather than self-disclosure or extensive cooperation, as central to a favorable outcome. Southern Glazer, the largest US liquor distributor, faced a major California kickback and bribery scheme involving five former employees, fabricated records, sham agreements, and luxury benefits to retailers and others, along with alleged tax impacts. The company resolved the matter with a $12.5 million payment and a two-year NPA requiring the CEO and CCO to certify program effectiveness. Tom and Matt review how the NPA affirms DOJ’s Evaluation of Corporate Compliance Programs as still relevant and detail remediation steps: major headcount and budget increases, upgraded compliance leadership, audits of marketing spend, enhanced training, strengthened third-party controls and AP payment blocks, outside reviews, and tone-at-the-top messaging.
Key highlights:
- Southern Glazer Case Setup
- Industry Risks and Scheme
- ECCP Guidance Still Matters
- Program Overhaul Timeline
- Concrete Remediation Metrics
- DOJ Signals Under Trump Era
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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Whistleblower Resolution Delays Is Justice Denied
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a GAO audit of the Department of Homeland Security’s whistleblower retaliation program.
They use it as a case study for corporate compliance officers. DHS employees can report internally via the Office of Inspector General hotline or externally to the Office of Special Counsel. However, the GAO review focused on DHS’s internal process, where the OIG’s Whistleblower Protection Division (eight investigators) investigates retaliation and, if substantiated, sends cases to the Office of the Secretary and ultimately the DHS Secretary for corrective action. Although targets are six months for investigation and 30 days for secretarial action, GAO found investigations averaged 3.2 years (some up to six) amid rising complaint volumes, turnover, and evidence-gathering challenges. Meanwhile, none of the 11 substantiated cases were decided within 30 days because of missing written procedures and no designated accountable official—showing how delayed resolution erodes reporting culture and “institutional justice.”
Key highlights:
- Why the GAO Report Matters
- DHS Whistleblower Program Structure
- Timeline Expectations vs. Reality
- Compliance Lessons and GAO Value
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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Governing Agentic AI: DFS Cyber Risk Assessments, EU AI Act Accountability, and the Inventory Problem
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them fully and uncover hard-hitting …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them fully and uncover hard-hitting compliance insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the growing compliance and cybersecurity challenges posed by agentic AI.
They focus on New York Department of Financial Services (DFS) guidance on cybersecurity risk assessments and a European survey Kelly cites. They argue DFS’s rule, requiring annual or as-needed reassessments after significant technology and threat changes and maintaining an accurate IT asset inventory, implicitly compels organizations to identify and track AI agents, even though agents are not mentioned. Kelly cites a Veeam Software survey of 1,000+ European executives reporting limited visibility into employee-created autonomous AI workflows and AI interactions with sensitive data, complicating EU AI Act requirements for human accountability. The conversation compares potential governance models to Sarbanes-Oxley sub-certifications and enterprise software management, questions whether CISOs can certify compliance amid decentralized agent creation, and notes potential enforcement avenues and the risks of industry self-regulation.
Key highlights:
- Why DFS Guidance Matters
- Risk Assessments Meet Agents
- Accountability Under EU AI Act
- SOX Style Governance Model
- Enforcement and Self-Regulation
Resources:
Matt in Radical Compliance (2 posts)
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcasts, and a Top 12 Risk Management Podcasts. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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Clippers Salary-Cap Circumvention: Sham Endorsements, Contract Red Flags, and Compliance Lessons
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the NBA’s sanctions against the Los Angeles Clippers for a salary-cap circumvention scheme tied to Kawhi Leonard.
In this delicious set of compliance imbroglios, senior management, including owner Steve Ballmer, allegedly arranged sham endorsement deals with four business partners and offsetting Clippers business to funnel about $18 million in extra compensation, plus improperly pay Leonard’s personal expenses. Tom and Matt review the Wachtell Lipton 36-page investigation detailing sparse contracts, unusual counterparties, rapid deal timing, and incriminating emails (including from Gillian Zucker), as well as recidivism after a similar 2019 violation. Penalties include a $30 million team fine, Leonard’s $700K fine, loss of first-round picks for five years, and suspensions for Ballmer, Zucker, and the basketball operations executive. Meanwhile, Ballmer denies wrongdoing and says the Clippers will file an appeal. They highlight contract-management and third-party due diligence lessons from FCPA-style guidance, the need to analyze patterns across multiple agreements, and the value of strong compliance roles in pro sports.
Key highlights:
- NBA Scandal Overview
- How The Scheme Worked and Why Salary Caps Matter
- Sham Contracts = Red Flags
- Paper Trail and Intent
- Recidivism and Tone at the Top
- Contract Patterns Lessons
Resources:
Matt in Radical Compliance
Tom in the FCPA Compliance and Ethics Blog
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and w3 Awards, all for podcast excellence.
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Broken Execution in Day-to-Day Compliance Operations – The BAE Enforcement Action
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. 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 discuss the recent BAE export control enforcement action.
Matt views the BAE export control enforcement action as a strong example of how ITAR compliance failures often stem from routine breakdowns in day-to-day operations rather than dramatic smuggling schemes. He notes that BAE’s U.S. subsidiary sent technical information and services overseas without proper licenses, including to China and even some allied countries, showing that export controls apply to both data and services, not just physical weapons. Kelly argues that the case reveals common compliance weaknesses such as poor training, unclear procedures, weak system warnings, and employee turnover that can leave staff unsure of the rules. His broader point is that companies in export-controlled industries must maintain current licenses and build strong, monitored compliance programs because governments will continue using export controls as an important geopolitical tool.
Key highlights:
- ITAR data shipments trigger BAE’s $36 million penalty
- Broken execution in day-to-day compliance operations
- Export-control warnings before sensitive file transmission
- Missing Red-Flag Prompts in Export Control System
- Self-Disclosed, Cooperated, Remediated, Monitored by Another Name
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.
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AI for Compliance: Lessons from Teaching Cohorts
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for some …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. 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 discuss Kelly’s collaboration with Ethena to run short, paid online AI classes for compliance professionals.
Since May, there has been an excellent AI training for compliance professionals, covering vibe coding, content/video generation, and data analytics with hands-on exercises using dummy or public data. Kelly says his biggest takeaway has been how much AI education is still needed and that many compliance teams are only scratching the surface, despite fears that “everyone else” is further along. They review common tools but emphasize that success depends more on the inputs and outputs, data readiness, clear use cases, and acting on results than on which model is chosen. They also address governance, security, privacy, maintenance, technical debt, costs and token budgets, and the need to involve compliance, which often leads to AI governance. The episode ends with reflections on Dolly Parton’s leadership and a story about her retaining rights to the hit song “I Will Always Love You.”
Key highlights:
- AI Class Overview
- AI Skills Gap Reality Check
- Good Enough to Start
- AI Angst and Cost Questions
- Why Compliance Should Lead AI Governance
- Dolly Parton Tribute
Resources
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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Compliance Implications of DOJ’s New Fraud Division and McDonald Memo
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them in greater depth and uncover …
Notas do episódio
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them in greater depth and uncover hard-hitting insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ’s “McDonald Memo.”
This DOJ Memo outlines a new Trump administration fraud division that broadly claims jurisdiction over “all types of fraud,” potentially reshaping DOJ enforcement and creating uncertainty about overlapping authority with existing divisions (e.g., antitrust). They review five priority areas: a. public trust/financial integrity fraud (procurement, bid rigging, grants, social welfare), b. healthcare fraud, c. internal revenue fraud, d. global trade and commerce fraud (tariffs/customs), and e. an undefined “corporate misconduct” category. From a compliance perspective, they urge companies to reassess risk areas (healthcare, importers, and government contractors), strengthen third-party oversight and documentation, and “pressure test” compliance programs with transparency and recordkeeping. They also warn that politicized enforcement and unclear guidance—such as on cartel-related liability—complicate compliance strategy and may tempt leaders to treat settlements as a cost of doing business.
Key highlights:
- McDonald Memo Overview
- Fraud Division Scope and Uncertainty
- Five Fraud Categories Explained
- Corporate Misconduct Questions
- Compliance Program Impacts
- Documentation as Defense
- Mexico Cartels and Strict Liability
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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Ted Lasso, Culture and Compliance
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. Looking for some …
Notas do episódio
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. 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 celebrate the return of Ted Lasso for Season 4.
Tom and Matt begin with why Ted Lasso resonates with compliance officers as a study of workplace dynamics, leadership, and building a culture of trust. They highlight how Ted focuses on coaching people and shaping club-wide culture through “thousands of imperceptible moments,” culminating in “total football,” where shared expectations and mutual support enable improvisation and performance. They connect this to compliance goals of embedding ethics so employees can handle new situations on the fly and to Jim Collins’ “level five” leadership and humility, illustrated by Ted renaming Trent Crimm’s book from “The Ted Lasso Way” to “The Richmond Way.” They also link the show to the military OODA loop (observe, orient, decide, act) as a model for empowered decision-making within clear objectives and boundaries and preview Season 4’s shift to Ted coaching a women’s team.
Key highlights:
- Ted Lasso Returns Season Four
- Culture and Trust at Richmond
- Total Football and Compliance
- The Richmond Way Leadership Lesson
- Level Five Humility
- OODA Loop Meets Compliance
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence.
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FinCEN’s $125MM UBS AML Order: A Culture and Resourcing Failure
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. Looking for some …
Notas do episódio
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. 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 discuss a newly issued FinCEN consent order sanctioning UBS Financial Services, the U.S. broker-dealer subsidiary of UBS.
It is a $125 million penalty, the largest FinCEN fine against a broker-dealer, for extensive anti-money laundering failures. They highlight weak transaction monitoring and suspicious activity reporting (SAR) processes, poor customer due diligence, inadequate wire-transfer data collection, and data governance gaps that led to under-reporting and hindered FinCEN’s ability to build a complete money-laundering picture. The order notes UBS failed to monitor more than 50,000 foreign-currency wires totaling over $10 billion and did not disclose ongoing deficiencies discovered after a 2018 $14 million FinCEN action requiring fixes by 2021, with problems traceable back to 2004 and not addressed until 2023. They frame the matter as a tone-at-the-top and resourcing failure, compare it to other enforcement actions (including a recent SEC fine against Merrill Lynch), and suggest a future deeper dive after reviewing the full order.
Key highlights:
- What UBS Got Wrong
- Scale Of The Failures
- Board Oversight and Resourcing
- Data Governance Breakdown
- SARs, Metrics, and AI Talk
- Takeaways and Next Steps
Resources:
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence.
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Scoular Company FCPA Settlement: Cartel Links, Border Trade Risks, and Compliance Lessons
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 it more fully. Looking for some …
Notas do episódio
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 it more fully. 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 discuss the recent FCPA resolution with the Scoular Company. Both Tom and Matt have blogged on this matter, so check out the Resources link below for additional discussions.
The recent FCPA enforcement action against Scoular Company involved a $10.2 million payment and a three-year deferred prosecution agreement over bribes by third-party customs brokers to Mexican border officials to expedite cross-border shipments. DOJ emphasized alleged cartel connections, including a strong statement from the U.S. Attorney for the Western District of Texas, which raised questions about expanded local U.S. attorney involvement and how cartel or potential FTO designations could heighten trade and compliance risks. The company received no voluntary self-disclosure credit but got a 25% discount, with remediation cited (including dropping brokers and strengthening tone at the top). They highlight off-channel WhatsApp use, the lack of released key documents (DPA, statement of facts, criminal information), and practical compliance takeaways on third-party oversight, data analytics, and risk assessments.
Resources:
Matt in Radical Compliance
Tom in FCPA Compliance and Ethics Blog
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.
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The Slaughter Ruling, Regulatory Volatility and a Healthcare Compliance Fraud Case
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 it in greater depth. Looking for some …
Notas do episódio
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 it in greater depth. 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 discuss the June 29 Supreme Court decision in Trump v. Slaughter.
This decision upheld the president’s power to fire independent agency commissioners at will (with a carve-out for the Federal Reserve), overturning long-standing protections from Humphrey’s Executor. Kelly argues the ruling will politicize and degrade regulatory agencies, deter qualified minority-party commissioners, increase rulemaking volatility, and shift power away from Congress toward courts as rules are challenged. As an example, they cite the SEC’s proposal to allow semi-annual rather than quarterly reporting, which drew about 80,000 comments, with roughly 99% opposed, yet they predict it may proceed and later be reversed, creating compliance burdens. They then cover Georgia author Jean Wilson, sentenced to 10 years for a $66 million Medicare fraud scheme while writing healthcare compliance books.
Key highlights:
- The Slaughter Ruling
- Regulatory Volatility Ahead
- Who Will Serve as Commissioners
- Fed Carve-out and Court Power
- Compliance Impact and No Easy Answers
- Healthcare Compliance Fraud Story (Or is it from The Onion?)
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.
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Survey Finds Widespread Retaliation Against Compliance Officers
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. Looking for some …
Notas do episódio
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. 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 discuss the recently released Radical Compliance, Case IQ, and Compliance Week-sponsored survey of more than 325 compliance professionals quantifying retaliation against compliance officers.
Matt reports that 70% say they have suffered retaliation (79% including those unsure), 67% experienced it more than once, and women report slightly higher rates than men. Common retaliation includes exclusion from meetings (64%), being badmouthed (59.5%), and unwanted role changes (49%), while 28% report being fired. Fear is significant: 36% are uncomfortable raising concerns at their current employer, and 48% have been stopped from doing so at some point. Among those reporting retaliation to management, the responses were poor: 53% saw no action, 21% saw investigations without a remedy, and only 4% felt management supported them. Few go to regulators or sue, though two-thirds of the small group who sued after firing reported satisfactory outcomes. They suggest structural protections such as disclosure of CCO departures, contract/termination safeguards like those in Indian banking rules, and updates to DOJ guidance.
Key highlights:
- Headline Findings
- Key Stats Breakdown
- Types of Retaliation
- Career Impact Stories
- Protection Ideas
- Human Toll and Caveats
Resources
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.
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Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement
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 it in greater depth. Looking for some …
Notas do episódio
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 it in greater depth. 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 discuss the recent Bosch export controls enforcement action involving two German subsidiaries that sold about $72 million in advanced microsensors and software to Huawei from 2020 to late 2024
Their actions violate U.S. export controls tied to the Foreign Direct Product Rule and 2020 “footnote one” restrictions. Although Bosch voluntarily self-disclosed, cooperated, remediated, disgorged profits, and received a DOJ criminal Declination, BIS imposed a $36.1 million civil penalty, citing fundamental compliance failures: an understaffed and underqualified export controls function, confusion between the de minimis rule and the foreign direct product rule (which has no de minimis exception), and mishandling repeated external warnings from business partners and suppliers. They highlight internal control and communication breakdowns (including external signals) and the need to build specialized export/sanctions compliance capacity, noting BIS issued a compliance framework in 2020 and offers training.
Key highlights:
- Bosch case overview
- Understaffed compliance fallout
- Ignored partner warnings
- Declination and remediation
- COSO signals and controls
- Building export compliance muscle
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance Blog: Part 1, Part 2, Part 3, Part 4, and Part 5 posts on Thursday, June 25.
Tom
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OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank
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 it in greater depth. Looking for some …
Notas do episódio
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 it in greater depth. 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 discuss a recent OFAC enforcement action fining FTI Consulting $1.05 million for a sanctions violation involving indirect dealings with Russia’s state-owned VTB Bank.
FTI provided economic analysis for VTB in litigation, but, knowing VTB was sanctioned, used a law firm as an intermediary to invoice and receive payment, which OFAC said does not avoid liability because prohibitions apply to indirect transactions as well as direct ones. OFAC doubled the base penalty of $525,000 explicitly to promote future compliance by similarly situated companies, signaling strong disapproval of “middleman” structures. The case also involved unpaid invoices that became an impermissible extension of credit to a sanctioned entity, highlighting the need for rigorous contract and payment-term review beyond basic sanctions screening and for dedicated sanctions expertise.
Key highlights:
- Introducing the OFAC Case
- Middleman Billing Scheme
- Why Screening Misses Indirect Risk
- Did Compliance Approve It?
- OFAC Expectations and Capability
- Penalty Doubled Warning Shot
- Unpaid Invoices as Credit Extension
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.
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Why the Compliance Job Market Feels Frozen
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 it in greater depth. Looking for some …
Notas do episódio
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 it in greater depth. 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 discuss a recent slowdown in compliance and internal audit hiring, with more layoffs and fewer job openings over the last several months.
Matt attributes the “frozen” market to broader economic uncertainty, tariffs, the war in Iran, which is driving higher energy costs, and erratic regulatory enforcement, all of which, combined with executives’ indecision about AI’s costs and impact, lead companies and employees to avoid change. They note structural competition at senior levels due to a larger, more experienced talent pool and the limited number of top roles, while acknowledging opportunities in compliance-adjacent paths such as HR, legal, governance, and integrity functions, depending on experience and credentials. Matt suggests focusing on interpersonal and cross-functional skills AI can’t replace and highlights continued demand in trade compliance, whistleblowers, and anti-fraud/False Claims Act work.
Key highlights:
- Compliance Job Market Shift
- Why Hiring Feels Frozen
- AI and Executive Uncertainty
- Talent Supply and Senior Roles
- Career Moves and Branding
- Where Hiring Still Happens
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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An SEC Rollback and a Tribute to Barney Frank
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 it more fully. Looking for some …
Notas do episódio
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 it more fully. 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 discuss SEC Chair Paul Atkins’ proposals to overhaul filer categories and sharply reduce corporate reporting and governance obligations, including SOX 404B internal control testing and Dodd-Frank say-on-pay votes, alongside a companion proposal to allow semi-annual instead of quarterly reporting.
Matt explains the shift to only two categories, raising the large accelerated filer threshold to $2B market cap, eliminating smaller reporting company status, and leaving roughly 80% of public companies as non-accelerated filers with reduced disclosures (e.g., two years of audited financials). They note a five-year IPO grace period, dubbed the “Elon exemption”, that could cover large new issuers such as SpaceX, OpenAI, and Anthropic. They warn of weakened investor protection, reduced enforcement, and significant impacts on compliance and culture. The episode closes with reflections on Barney Frank’s intellect, style, and Dodd-Frank legacy.
Key highlights:
- Atkins Rollback Overview
- New Filer Categories and Elon Exemption
- Investor Protection Fallout
- Compliance Culture Impacts
- Remembering Barney Frank
Resources:
Matt on Radical Compliance
Tom in Compliance Week
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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The DOJ Trainwreck and the Rising Risk Calculus for Compliance and Self-Disclosure
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 it more fully. Looking for some …
Notas do episódio
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 it more fully. 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 discuss how internal dysfunction at the U.S. Department of Justice is creating uncertainty for corporate compliance teams and corporations more generally.
Focusing on a reported turf battle between the long-standing Fraud Section in the Criminal Division, established in 1955 and central to FCPA enforcement and compliance guidance, and a newly created national Fraud Division, which was initially framed as targeting government benefits fraud. They argue that the reorganization could drain expertise, reduce future DOJ guidance, and distort enforcement into politically selective actions, citing IBM’s $17 million settlement, an EEOC case involving The New York Times and Smartmatic, and Smartmatic’s experience. They also highlight DOJ staffing losses with a net 20% fewer lawyers, loss of experienced attorneys, reliance on inexperienced hires and bonuses, and warn that the volatility may chill voluntary self-disclosure despite DOJ messaging encouraging it.
Key highlights:
- DOJ Train Wreck Overview
- Fraud Section vs Fraud Division
- Political Enforcement Reality
- Self-Disclosure Gets Riskier
- What Companies Should Do Now
Resources:
Matt on Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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Ohio State and Improper Requests by a President
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 the subject more fully. Looking for some …
Notas do episódio
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 the subject more fully. 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 discuss the recent departure of the President of the Ohio State University.
Matt and Tom raise a compliance-focused question: how should an employee respond after receiving a request that may implicate an improper relationship between a company president and his girlfriend? They highlight whether an employee should question or report a potentially inappropriate relationship based solely on the request or whether doing so would go too far without more substantive evidence. Their discussion emphasizes that addressing such concerns can be a delicate conversation for employees to navigate.
Resources:
Matt on Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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Navigating DOJ's Evolving Self-Disclosure Strategies
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 the subject more fully. Looking for some …
Notas do episódio
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 the subject more fully. 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 discuss a recent Law360 post by Hui Chen on the evolving calculus for self-disclosure.
Hui Chen’s insights into the Department of Justice’s (DOJ) evolving self-disclosure strategies are crucial for companies navigating the complexities of compliance in today’s uncertain regulatory environment. As a former DOJ compliance counsel and a Microsoft compliance officer, Chen emphasizes the challenges posed by a politicized, understaffed DOJ, urging companies to reassess their compliance programs amid shifting enforcement dynamics. Tom and Matt echo Chen’s concerns regarding the DOJ’s current state. Tom, acknowledging Chen’s expertise, highlights the impact of the department’s politicization and understaffing on the effectiveness of compliance efforts, while Matt underscores the importance of proactive self-disclosure despite uncertainties, stressing the potential risks of inaction under the current administration. Both agree that the fractured nature of the DOJ requires a reevaluation of traditional compliance and self-disclosure strategies.
Key highlights:
- Navigating DOJ Self-Disclosure Strategies with Wei Chen
- Justice Department’s Impact on Corporate Prosecutions
- Mitigating Criminal Violations through Self-Disclosure
- Benefits of Self-Disclosure in Corporate Enforcement
Resources:
Hui Chen on Law360 (sub req’d)
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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Banking Regulators Cut Model Risk Guidance: Implications for Compliance, Audit, and AML Oversight
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 it more fully, and looking for some …
Notas do episódio
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 it more fully, and 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 discuss new Federal Reserve, FDIC, and OCC model risk management guidance issued late Friday, arguing it replaces detailed, bright-line expectations with thin, principles-based language.
They contrast the prior OCC guidance (109 pages) with the new 12-page document, saying it describes model risk governance abstractly but offers little direction on what banks should do, leaving decisions about materiality and oversight to management. They highlight practical consequences for bank compliance and internal audit, including reduced leverage to insist on prudent governance, potential weakening of AML model oversight under the strict-liability Bank Secrecy Act, and the risk of more arbitrary enforcement amid reduced regulatory staffing. They also note that the guidance excludes AI models, with future AI guidance promised only through a later comment process.
Key highlights:
- From 109 pages to 12
- Principles vs specifics debate
- Internal audit sidelined
- Regulators and capacity cuts
- AI models left out
Resources:
Matt on Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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Surveying Retaliation Against Compliance Officers
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 it more fully. Looking for some …
Notas do episódio
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 it more fully. 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 discuss a new anonymous Radical Compliance survey, launched with Case IQ and Compliance Week, to quantify retaliation against compliance officers who raise compliance concerns to senior management.
The survey asks what misconduct was reported, who retaliated, what forms of retaliation took place, such as firing, demotion, harassment, budget cuts, blacklisting, and what actions followed. Matt also encourages responses even from those who have not experienced retaliation. Tom and Matt have previously discussed anecdotally but have not systematically studied, and plan to publish their findings and host a webinar later in the spring, likely in June. They also discuss potential structural protections informed by data, such as disclosure expectations around CCO departures (e.g., 8-K concepts) and contract/regulatory-approval models like those in India’s banking sector, and suggest that the findings could inform DOJ views on compliance autonomy and effective compliance programs.
Key highlights:
- Survey Launch Explained
- Retaliation Questions
- Why This Study Matters
- Defining Prevalence
- Using Findings for Change
- Final Call to Participate
Resources:
Matt on Radical Compliance
Survey on Retaliation Against Compliance Professionals
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.
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Duty Owed vs. Material Nonpublic Information: Prediction Markets and Compliance
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 …
Notas do episódio
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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the prediction markets and what they mean for compliance.
Tom and Matt focus on the phrase “violation of a duty owed” by employees and notes that this standard appears significantly broader than traditional insider trading laws. They explain that insider trading law centers on the disclosure of material nonpublic information, whereas a “duty owed” framework emphasizes the underlying duty itself. Because “duty owed” could encompass many different types of obligations beyond material nonpublic information, the speaker highlights the potential compliance implications and expresses interest in exploring a related hypothetical scenario.
Resources
Tom
A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.
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AI-Driven SOC Audits and the Growing Trust Gap
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 …
Notas do episódio
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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss concerns that AI-driven automation may be weakening SOC 1 and SOC 2 audits used to assure vendor financial reporting controls and cybersecurity/privacy controls.
They focus on allegations by an anonymous whistleblower (“Deep Delver”) that tech startup Delve fabricates audit documentation with AI and relies on audit firms to rubber-stamp reports, claims Delve denies, potentially undermining trust in hundreds of SOC reports. Beyond Delve, they warn that startups are “fracturing” the traditional SOC audit model, driving timelines and costs from months and tens of thousands of dollars to days and a few thousand, encouraging check-the-box, low-quality audits, sometimes via little-known overseas firms. They note regulators are unlikely to intervene, leaving companies to reassess due diligence and the real assurance value of SOC reports.
Key Highlights
· Delve Whistleblower Claims
· Red Flags in Audit Firms
· How SOC Audits Work
· Check the Box Trap
· Regulatory Blind Spots
· What Companies Should Do
Resources
Delve accused of misleading customers with ‘fake compliance’ in YaHoo!Finance
Delve response
Promises of ‘fast and easy’ threaten SOC credibility in Journal of Accountancy
Tom
A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.
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