The Bonkers Allegations Against Binance

By Matt Kelly | March 29, 2023 |

\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…

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Musings on Messaging Apps

By Matt Kelly | March 27, 2023 |

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…

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compliance jobs

Compliance Jobs Report: March 24

By Matt Kelly | March 24, 2023 |

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!…

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More on ‘Extraordinary’ Cooperation

By Matt Kelly | March 23, 2023 |

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…

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Dispatches From SCCE Europe 2023

By Matt Kelly | March 22, 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…

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Congress Tries Anew on Whistleblower Fixes

By Matt Kelly | March 20, 2023 |

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…

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Silicon Valley Bank: The Oversight Debacle

By Matt Kelly | March 19, 2023 |

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…

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Suggestions for Small Compliance Programs

By Matt Kelly | March 17, 2023 |

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…

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compliance jobs

Compliance Jobs Report: March 17

By Matt Kelly | March 17, 2023 |

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…

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Another Cyber Disclosure Sanction

By Matt Kelly | March 15, 2023 |

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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About Us

Technically, Radical Compliance is the personal blog of Matt Kelly, long-time writer and observer of the corporate compliance and GRC scene. I was a writer, editor, and publisher at Compliance Week, 2003 through 2015; some of you may know me from my career there. I also speak frequently at compliance conferences and other events, and will pretty much shoot the breeze on any compliance topic with anyone who asks.

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