Posts by Matt Kelly
The Bonkers Allegations Against Binance
\You may have heard by now that earlier this week, regulators filed a lawsuit against cryptocurrency trading platform Binance. I just read the complaint, and have good news: however whacko your own company’s bad habits might be, the allegations against Binance are way more crazy. The regulator responsible for this bombshell of bizarreness is the…
Read MoreMusings on Messaging Apps
Compliance officers have a lot to ponder in the Justice Department’s recent updates to its guidance for corporate compliance programs. The most demanding issue, however, might be how the department wants companies to handle employees’ use of messaging apps. It’s going to be quite the challenge. Clearly messaging apps are a priority for the Justice…
Read MoreCompliance Jobs Report: March 24
This week the Compliance Jobs Report notes new compliance leaders at Mastercard and Danske Bank; chief audit executive moves at CVS Health and University of Utah; and other promotions and personnel moves elsewhere. Job leads this week are in medical devices, cash, and consumer goods. Meme of the Week goes out to defective compliance programs!…
Read MoreMore on ‘Extraordinary’ Cooperation
Still wondering what the Justice Department means when it says it wants “immediate” self-disclosure of corporate misconduct and “extraordinary” cooperation and remediation for severe FCPA cases? Good news: we now have a bit more understanding of those terms, straight from the Justice Department official who coined them. Assistant attorney general Kenneth Polite, who has been…
Read MoreDispatches From SCCE Europe 2023
The Society of Corporate Compliance & Ethics is holding its annual European conference this week in Amsterdam. Alas, Radical Compliance could not be there in person, so we’ve been scouring social media to see what others have been saying about the event. Below are a few names, faces, photos, and dispatches from the Netherlands! Roughly…
Read MoreCongress Tries Anew on Whistleblower Fixes
Several big names in the Senate have filed legislation that would clarify the protections for whistleblowers who first report their concerns to internal compliance teams and force the SEC to decide whistleblower awards more quickly. Dubbed the “SEC Whistleblower Reform Act,” Sens. Elizabeth Warren, D-Mass., and Chuck Grassley, R-Iowa, filed the bill last week along…
Read MoreSilicon Valley Bank: The Oversight Debacle
Today I want to return to the collapse of Silicon Valley Bank. Everyone has been wondering how the bank met its sudden demise, and whose poor oversight allowed that to happen. Now we have more details to help answer those questions — and, ideally, avoid a repeat performance elsewhere. People first trained their fire on…
Read MoreSuggestions for Small Compliance Programs
At some point in their careers, most compliance officers will spend time working at or running a small compliance program. So when I had the chance earlier this month to moderate a webinar on that subject, I took detailed notes. I suspect many of the frustrations and issues voiced by those small-company compliance officers will…
Read MoreCompliance Jobs Report: March 17
We have quite the international Compliance Jobs Report this week. We have updates from Credit Suisse, Mastercard, several global pharma businesses, Toyota, and the best-named aerospace company ever! This year’s list of World’s Most Ethical companies is out, and Meme of the Week goes out to everyone with tight budgets. As always, thank you to…
Read MoreAnother Cyber Disclosure Sanction
Words matter in SEC filings. The Securities and Exchange Commission gave us another example of that point recently when it fined a technology company $3 million for misleading disclosures about a ransomware attack the company had suffered — and the confusion arose from how the company used the word “could.” The company in question is…
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