Épisodes

  • The DOJ's Inconsistent Stance on White Collar Crime and FCPA Enforcement

    The DOJ's Inconsistent Stance on White Collar Crime and FCPA Enforcement
    Dec 17 2025
    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 look at the mixed and muddled messages coming out of the DOJ on FCPA and white collar enforcement. We discuss recent signals from the DOJ suggesting a reinvigorated stance on corporate malfeasance, juxtaposed with actions like the pardoning of convicted offenders which muddle the overall message. The conversation covers Deputy Attorney General Todd Blanche's inflammatory speech on the seriousness of FCPA actions, the controversial pardons by President Trump, and the apparent selective enforcement against foreign versus U.S. companies. The episode examines the ramifications of these mixed signals for compliance professionals, companies, and whistleblowers, emphasizing the need for clearer guidance and consistency from the DOJ. Key Highlights · Mixed Messages from the Justice Department on FCPA and White Collar Enforcement · Deputy Attorney General's Angry Speech · Controversial Pardons and Their Implications · ZTE and FCPA Charges · Inconsistencies and Compliance Challenges · The Impact of Presidential Pardons on Compliance 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 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    23 min
  • Live from the Floor of ACI

    Live from the Floor of ACI
    Dec 10 2025
    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 their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference. Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ’s focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severn Wirz’s new book, Bribery Beyond Borders, on the historical context of FCPA enforcement. Key highlights: FCPA Enforcement Realities White Collar Crime and DOJ Priorities Cartels and Corruption Whistleblower Program Insights Book Signing and Historical Context 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 a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    20 min
  • Understanding SFO Guidance and Compliance Program Assessments

    Understanding SFO Guidance and Compliance Program Assessments
    Dec 3 2025
    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 recently released Serious Fraud Office (SFO) guidance on compliance programs. Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances. Key highlights: Introduction to SFO Guidance Comparing SFO Guidance with US Standards Uncertainty in SFO's Expectations Holistic Assessment by SFO Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    20 min
  • Uncovering FCPA Violations: Millicom's Complex Case Involving Drug Cartel Funds

    Uncovering FCPA Violations: Millicom's Complex Case Involving Drug Cartel Funds
    Nov 19 2025
    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 intricate details of a recent FCPA enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala. The discussion uncovers how Millicom's joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ’s earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom's operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions. Key highlights: Details of the FCPA Enforcement Action Millicom’s Joint Venture in Guatemala Self-Disclosure and DOJ’s Response Timeline of Events and Corruption Details Drug Trafficking and Bribery Connections Implications and Compliance Lessons 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 a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    24 min
  • The Atlanta Hawks Scandal: Lessons in Financial Misconduct

    The Atlanta Hawks Scandal: Lessons in Financial Misconduct
    Nov 12 2025
    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 basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action. The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity. Key Highlights · Lessons from Atlanta Hawks Fraud Case · Least Privilege Access for Preventing Financial Fraud · Financial Data Examination for Fraud Detection · Executives' Lavish Misconduct: Lessons in Ethics 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 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    26 min
  • Incentives in Compliance: Structuring Effective Compensation Plans

    Incentives in Compliance: Structuring Effective Compensation Plans
    Nov 5 2025
    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. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the intricacies of integrating incentives into corporate compliance programs. Matt shares insights from a recent webinar and blog posts, discussing how companies can encourage ethical behavior through executive compensation plans, performance bonuses, and other incentive schemes. The conversation explores the Justice Department’s guidelines on executive compensation, the intricacies of designing these programs to align with industry-specific risks, and the implications for various levels of management. They also examine the challenges of establishing meaningful compliance metrics and striking a balance between compliance incentives and overall business objectives across multiple sectors. Key highlights: The Role of Incentives in Compliance Programs Structuring Executive Compensation for Compliance Challenges and Nuances in Incentive Programs Incentives for Different Business Models Compensation Types and Ethical Behavior 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 honored with a Davey, Communicator, and W3 Award, all for excellence in podcasting. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    24 min
  • The NBA Betting Scandal - Lessons for the Compliance Professional

    The NBA Betting Scandal - Lessons for the Compliance Professional
    Oct 29 2025
    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 unfolding NBA betting scandal and explore what it all might mean for the compliance professional. Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals. Key highlights: NBA Betting Scandal Overview Historical Context and Data Analytics Conflict of Interest and Risk Assessment Investigation and Compliance Strategies Resources: Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠ 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 a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    32 min
  • The End of Self-Disclosure? The Criminal Indictment of Smartmatic

    The End of Self-Disclosure? The Criminal Indictment of Smartmatic
    Oct 22 2025
    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 rare occurrence of a company, Smartmatic, being added to an existing indictment for FCPA violations. They explore the unusual circumstances surrounding this case, including the political sensitivity of Smartmatic, its ongoing litigation with Fox News, and the potential implications for corporate voluntary self-disclosure under the current administration. They delve into the changes in DOJ criteria for FCPA prosecutions and raise concerns about selective prosecution and the broader impact on compliance strategies. Key highlights: Overview of Smart Medic Indictment Political Context and Conspiracy Theories Implications for Compliance and Self-Disclosure Concerns About Selective Prosecution Resources: 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 a Davey, Communicator, and W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    24 min