Compliance into the Weeds

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 celebrate the return of Ted Lasso for Season 4.

Tom and Matt begin with why Ted Lasso resonates with compliance officers as a study of workplace dynamics, leadership, and building a culture of trust. They highlight how Ted focuses on coaching people and shaping club-wide culture through “thousands of imperceptible moments,” culminating in “total football,” where shared expectations and mutual support enable improvisation and performance. They connect this to compliance goals of embedding ethics so employees can handle new situations on the fly, and to Jim Collins’ “level five” leadership and humility, illustrated by Ted renaming Trent Crimm’s book from “The Ted Lasso Way” to “The Richmond Way.” They also link the show to the military OODA loop (observe, orient, decide, act) as a model for empowered decision-making within clear objectives and boundaries, and preview Season 4’s shift to Ted coaching a women’s team.

Key Highlights

· Ted Lasso Returns Season Four

· Culture and Trust at Richmond

· Total Football and Compliance

· The Richmond Way Leadership Lesson

· Level Five Humility

· OODA Loop Meets Compliance

Resources

Matt 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 Award, all 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 a newly issued FinCEN consent order sanctioning UBS Financial Services, the U.S. broker-dealer subsidiary of UBS.

It is a $125 million penalty, the largest FinCEN fine against a broker-dealer, for extensive anti-money laundering failures. They highlight weak transaction monitoring and suspicious activity reporting (SAR) processes, poor customer due diligence, inadequate wire-transfer data collection, and data governance gaps that led to under-reporting and hindered FinCEN’s ability to build a complete money-laundering picture. The order notes UBS failed to monitor more than 50,000 foreign-currency wires totaling over $10 billion and did not disclose ongoing deficiencies discovered after a 2018 $14 million FinCEN action requiring fixes by 2021, with problems traceable back to 2004 and not addressed until 2023. They frame the matter as a tone-at-the-top and resourcing failure, compare it to other enforcement actions (including a recent SEC fine against Merrill Lynch), and suggest a future deeper dive after reviewing the full order.

Key highlights:

What UBS Got Wrong

Scale Of The Failures

Board Oversight and Resourcing

Data Governance Breakdown

SARs, Metrics, and AI Talk

Takeaways and Next Steps

Resources:

⁠USB Consent Order⁠

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 a Davey, Communicator, and W3 Award, all 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 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 recent FCPA resolution with the Scoular Company. Both Tom and Matt have blogged on this matter, so check out the Resources link below for additional discussions.

The recent FCPA enforcement action against Scoular Company involved a $10.2 million payment and a three-year deferred prosecution agreement over bribes by third-party customs brokers to Mexican border officials to expedite cross-border shipments. DOJ emphasized alleged cartel connections, including a strong statement from the U.S. Attorney for the Western District of Texas, which raised questions about expanded local U.S. attorney involvement and how cartel or potential FTO designations could heighten trade and compliance risks. The company received no voluntary self-disclosure credit but got a 25% discount, with remediation cited (including dropping brokers and strengthening tone at the top). They highlight off-channel WhatsApp use, the lack of released key documents (DPA, statement of facts, criminal information), and practical compliance takeaways on third-party oversight, data analytics, and risk assessments.

Resources:

Matt in Radical Compliance

Tom in FCPA Compliance and Ethics Blog

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, all 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 it in greater depth. 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 June 29 Supreme Court decision in Trump v. Slaughter.

This decision upheld the president’s power to fire independent agency commissioners at will (with a carve-out for the Federal Reserve), overturning long-standing protections from Humphrey’s Executor. Kelly argues the ruling will politicize and degrade regulatory agencies, deter qualified minority-party commissioners, increase rulemaking volatility, and shift power away from Congress toward courts as rules are challenged. As an example, they cite the SEC’s proposal to allow semi-annual rather than quarterly reporting, which drew about 80,000 comments, with roughly 99% opposed, yet they predict it may proceed and later be reversed, creating compliance burdens. They then cover Georgia author Jean Wilson, sentenced to 10 years for a $66 million Medicare fraud scheme while writing healthcare compliance books.

Key highlights:

The Slaughter Ruling

Regulatory Volatility Ahead

Who Will Serve as Commissioners

Fed Carve-out and Court Power

Compliance Impact and No Easy Answers

Healthcare Compliance Fraud Story (Or is it from The Onion?)

Resources:

Matt in 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, all 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 recently released Radical Compliance, Case IQ, and Compliance Week-sponsored survey of more than 325 compliance professionals quantifying retaliation against compliance officers.

Matt reports that 70% say they have suffered retaliation (79% including those unsure), 67% experienced it more than once, and women report slightly higher rates than men. Common retaliation includes exclusion from meetings (64%), being badmouthed (59.5%), and unwanted role changes (49%), while 28% report being fired. Fear is significant: 36% are uncomfortable raising concerns at their current employer, and 48% have been stopped from doing so at some point. Among those reporting retaliation to management, the responses were poor: 53% saw no action, 21% saw investigations without a remedy, and only 4% felt management supported them. Few go to regulators or sue, though two-thirds of the small group who sued after firing reported satisfactory outcomes. They suggest structural protections such as disclosure of CCO departures, contract/termination safeguards like those in Indian banking rules, and updates to DOJ guidance.

Key highlights:

Headline Findings

Key Stats Breakdown

Types of Retaliation

Career Impact Stories

Protection Ideas

Human Toll and Caveats 

Resources

Matt in 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, all for podcast excellence.
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