Compliance into the Weeds

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, 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 Matt’s recent experience at a compliance conference in Lithuania and engage in a thorough discussion about effective human oversight in AI systems.

They examine the recent guidance from the European Data Protection Supervisor (EDPS) on maintaining human oversight of automated decision-making processes, relating it to similar regulatory requirements in California. The conversation explores the implications for corporate compliance, IT, and audit professionals, highlighting the challenge of balancing AI efficiency with the need for effective human intervention to mitigate risks and ensure regulatory compliance.

Key highlights:

• Matt’s Experience in Lithuania
• AI Regulation in the EU and CCPA Amendments re: ADS and ADMT
• Effective Human Oversight in AI Systems
• Challenges in AI Control Design
• The Role of Compliance and Audit in AI Oversight

Resources:

Matt on Radical Compliance

Tom with a 5-Part podcast series on the CCPA Amendments on ADS/ADMT with Alyssa DeSimone on Life with GDPR

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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 Awards for podcast excellence.

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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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss into the implications of artificial intelligence, specifically the use of chatbots in compliance programs.  

Matt joins from Vilnius, Lithuania, where he is set to address a gathering of Baltic and Eastern European compliance professionals. The discussion centers around AI chatbots used for policy guidance, particularly the ethical concerns and potential risks of tracking individual employee inquiries and the possibility of violating whistleblower protection laws. Tom and Matt emphasize the importance of robust IT general controls and corporate culture in managing these new AI-powered compliance tools. They also address how regulators, like the Department of Justice, may evaluate the effectiveness of AI in compliance programs going forward.

 Key Highlights 

·      Exploring AI in Compliance

·      Chatbot Concerns and Whistleblower Anonymity

·      User Experience vs. Compliance Function Experience

·      Regulatory Expectations and Future of AI in Compliance

Resources

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 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 Awards for podcast excellence. 

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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. 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 bot attack on Cracker Barrel during its abortive name change imbroglio.

They explore the notion that social media risk is not a new concept, but rather an amplifier of existing risks for companies. It discusses the heightened potential for misinformation about a company’s values and how social media platforms have magnified this risk. Regulatory measures and accountability issues are addressed, with a nod to the role of prominent figures like Elon Musk. The episode underscores the inevitable, albeit unfair, reality of managing these amplified risks in today’s digital landscape.

Key highlights:

• Introduction to Social Media Risks
• Amplification of Existing Risks
• Challenges in Managing Misconceptions
• The Unavoidable Reality of Social Media Accountability

Resources:

Matt on Radical Compliance

Tom

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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 for podcast excellence.

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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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Trump administration’s recent H-1B visa reforms and their implications for corporate compliance officers.  

Highlighting the sudden and arbitrary policy changes, they discuss the potential chaos and confusion for businesses reliant on H-1B visas. They explore the economic ramifications, the threat of increased corporate costs, and the embedded risks of corruption. The episode underscores the broader issue of regulatory unpredictability under the Trump administration and advises compliance professionals on coping strategies in this volatile environment. 

Key Highlights 

·      H-1B Visas: Current Headlines

·      Understanding H-1B Visas

·      Trump Administration’s New H-1B Visa Policy

·      Policy Clarifications and Implications

·      Potential for Corruption 

Resources

Matt on Radical Compliance

Tom  

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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 Awards for podcast excellence. 

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Key highlights:

• The SCCE conference was well-attended with over 1300 participants.
• The absence of key representatives from the Trump administration was notable.
• Innovative presentations offered fresh perspectives on compliance topics.
• Compliance professionals must adapt policies to effectively support AI tools.
• Leadership changes at SCCE signal a new direction for the organization.

Resources:

Matt on Radical Compliance 

Tom

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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 for podcast excellence.

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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. 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 review a recent report from LRN on the state of Codes of Conduct.

This episode explores the multifaceted use of a corporate code of conduct, discussing its role as both a defensive and offensive tool. Tom and Matt emphasize the importance of managers talking about the code and view it as a substantive part of senior management’s dialogue on corporate culture. The conversation underscores the code’s utility in various contexts and advocates for its broader adoption within the organization.

Key highlights:

• Code as a Tool
• The Role of Managers in Code Discussion
• Senior Managers and Corporate Culture
• Versatility of the Code

Resources:

Matt on Radical Compliance

Tom

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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 for podcast excellence.

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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 of Compliance into the Weeds, Tom Fox and Matt Kelly a recent OFAC enforcement action against a Swiss-domiciled freight forwarding company, Fracht.

The case stands out for its complexity, involving a single, high-value transaction that exposed the company to significant sanctions risk through dealings with both Venezuelan and Iranian entities. Tom and Matt break down the compliance failures, the role of senior management, and the extensive remediation steps taken post-incident. This episode offers actionable lessons for compliance professionals on supply chain due diligence, the importance of compliance involvement in urgent deals, and the consequences of sidelining compliance functions.

Key Highlights

• OFAC Enforcement Details
• Anatomy of the Transaction
• Third- and Fourth-Party Risks
• Senior Management Involvement
• Compliance Failures & Supply Chain Visibility
• Remediation & Consequence Management

Key Takeaways for Compliance Professionals:

• Always involve compliance in high-value, urgent transactions.
• Ensure robust due diligence for all counterparties, including third- and fourth-party risks.
• Senior management must be accountable for compliance failures.
• Remediation should include policy updates, staff training, and ongoing oversight.

Key Highlights

Resources

Matt on Radical Compliance

Tom  

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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 Awards for podcast excellence. 

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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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Matt Kelly discuss the implications of thinning out middle management ranks in corporate America. 

Kelly’s blog post, inspired by a Wall Street Journal article, serves as the foundation for a broader discussion on how the reduction of managers impacts corporate culture, employee dynamics, and compliance programs. We explore the reasons behind this trend, such as the desire for agility or cost-cutting, and its effects on communication, institutional knowledge, and the role of compliance officers. We also touch on potential solutions, including the use of AI, enhanced training, and adaptive compliance strategies to mitigate the risks associated with fewer middle managers.

Key Highlights

·      Corporate America’s Managerial Shift

·      Implications for Corporate Culture

·      AI and Compliance Solutions

·      Institutional Knowledge and Risks

·      Compliance Takeaways and Final Thoughts

Resources

Matt on Radical Compliance

Tom  

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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 Awards for podcast excellence. 

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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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Matt Kelly discuss the recent University of Michigan football scandal. 

 They draw parallels to the infamous 2017 Houston Astros sign-stealing incident and examine the numerous compliance failures within Michigan’s football program. Highlighted issues include impermissible scouting, leadership failures by Jim Harbaugh, marginalization of the compliance function, and the NCAA’s ineffective enforcement. The conversation underscores crucial lessons for corporate compliance, emphasizing documentation, intern training, cooperation in investigations, and maintaining robust enforcement actions. 

Key Highlights 

·      Michigan Football Scandal Overview

·      Impermissible Scouting and Violations

·      Leadership Failures and Compliance Issues

·      NCAA’s Toothless Enforcement

·      Comparisons to Corporate Compliance

·      Lessons for Compliance Officers

 Ed. Note-I have written a 5-part blog post series on the UM Cheating Scandal. It is posting each day this week. You can check out the full series on my blog site, the FCPA Compliance and Ethics Blog. 

 Resources 

Tom  

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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. 

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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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss emerging concerns surrounding AI, particularly ChatGPT, in the realm of employee training. 

 Their discussion focuses on how AI, specifically the newest ‘Agent Mode’ of ChatGPT, could be used to take compliance training courses on behalf of employees, essentially allowing them to cheat. They debate the implications of this capability, touching on the historical context of cheating, the effectiveness of current training methods, and the need for new internal controls and strategies to adapt to these technological advancements. They also contemplate the future of training, potentially evolving into AI-driven bots that provide on-the-spot, micro-learning modules. The episode encourages compliance officers to thoroughly vet their training vendors to ensure measures are in place to prevent AI-enabled cheating. 

Key Highlights 

·      The Dark Side of AI in Compliance Training

·      AI’s Impact on Employee Training

·      AI’s Role in Training and Compliance

·      Future of AI in Corporate Training

·      Challenges and Considerations

 Resources

Matt Kelly in Radical Compliance

Tom  

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 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 Awards for podcast excellence. 

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