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. This week Matt and Tom take a deep dive into one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.
Some of the issues we consider are:
· How did this Fubar occur?
· What was the role of complexity?
· Why did the employees make this mistake?
· What about training?
· Where were internal controls?
· What is the ‘value for discharge’ defense?
· Does this all just come down to finders keepers?
· What are the compliance lessons?
Resources
Tom’s blog posts on the FCPA Compliance and Ethics Blog:
Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The Facts
Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned
The Citibank decision
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