Liquor Case Gins Up FCPA Lessons

By Matt Kelly | October 27, 2020 |

Here’s something you don’t see every day: the Justice Department hit spirits manufacturer Beam Suntory with a $19.5 million fine on Tuesday for a bribery scheme in India — where the company got an extra punch in the pocketbook for failure to cooperate fully or to coordinate the Justice Department FCPA investigation with a separate…

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internal control

Goldman Sachs, FCPA, and Internal Controls

By Matt Kelly | October 26, 2020 |

Now that we’ve all had the weekend to contemplate the massive Goldman Sachs FCPA enforcement action from last week (because that’s how we all spend our free time, right?), let’s return to an issue that’s been on my mind since the settlement was announced.  How does a company strengthen an internal control, when that control…

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compliance jobs

Compliance Jobs Report: Oct. 23

By Matt Kelly | October 23, 2020 |

The Compliance Jobs Report this week has new compliance chiefs at Google and Hormel Foods; a slew of promotions; and several work milestones to note. We have job openings in healthcare, data analytics, and storage space — and our Meme of the Week goes out to Borat! As always, thank you to all the compliance…

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Goldman Sachs’ Giant FCPA Deal

By Matt Kelly | October 22, 2020 |

All right compliance professionals, it’s here: Goldman Sachs has agreed to pay $4.3 billion to settle corruption charges for its role in the 1MDB scandal — making Wall Street’s premier investment bank responsible for the largest criminal penalty in FCPA history.  U.S. regulators announced the news today, although rumors of a settlement had been swirling…

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Citigroup, Part IV: Compliance Risk

By Matt Kelly | October 21, 2020 |

We finish our examination of the Citigroup enforcement action with a look at the issue most dear to compliance officers’ hearts: compliance risk, and how Citigroup needs to improve its compliance risk management function to meet regulators’ expectations. First, the backstory. On Oct. 7 the Office of the Comptroller of the Currency levied a $400…

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Citigroup, Part III: Better Board Oversight

By Matt Kelly | October 18, 2020 |

Today we return to Citigroup and its $400 million regulatory settlement from earlier this month, a case that offers a cornucopia of lessons for risk and compliance professionals. This time around, we consider what Citi’s board will need to do to rectify the bank’s poor internal governance.  First, let’s recap the case so far. The…

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JBS, Internal Controls, and the FCPA

By Matt Kelly | October 16, 2020 |

Meat-processing giant JBS has agreed to pay $283.3 million to settle a brazen FCPA bribery scheme, with fascinating lessons for the compliance professional if you can endure the headache-inducing facts of the case.  The Justice Department and the Securities & Exchange Commission announced the settlement Wednesday. JBS’ parent company J&F Investments, headquartered in Brazil, pleaded…

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compliance jobs

Compliance Jobs Report: Oct. 16

By Matt Kelly | October 16, 2020 |

A rather gossipy Compliance Jobs Report this week! We have news from the cryptocurrency world, a promotion at University of Wisconsin, and yet another compliance professional tapped to serve on a corporate board. Numerous work anniversaries to note, and job openings from tech to engineering to auto parts. Plus our Meme of the Week. As…

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PCAOB Member Uncorks on Agenda

By Matt Kelly | October 14, 2020 |

One of the five members of the Public Company Accounting Oversight Board blasted his own agency on Wednesday, saying that the regulator’s plans for the next 12 to 18 months are “a tragic mistake” that ignore the needs of investors and undermine the credibility of corporate financial reporting. The statement came from PCAOB board member…

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Mystery in Deaths of Four Liberian Auditors

By Matt Kelly | October 13, 2020 |

We have a grim reminder from Africa of the perils that risk assurance professionals face while fighting corruption: the chief auditor of the government of Liberia was found dead under mysterious circumstances over the weekend, and is the fourth Liberian government auditor to meet a suspicious end in two weeks.  According to local news reports,…

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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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