Compliance into the Weeds copertina

Compliance into the Weeds

Compliance into the Weeds

Di: Tom Fox
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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. Economia Gestione e leadership Management Politica e governo
Episodi
  • Survey Finds Widespread Retaliation Against Compliance Officers

    Survey Finds Widespread Retaliation Against Compliance Officers
    Jul 1 2026
    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 Instagram Facebook YouTube Twitter LinkedIn 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    26 min
  • Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

    Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement
    Jun 24 2026
    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 Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
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    27 min
  • OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank

    OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank
    Jun 17 2026
    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 Instagram Facebook YouTube Twitter LinkedIn 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    20 min
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