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. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.
Some of the issues we consider are:
The Bank’s compliance program was a paper program only.
Where was compliance?
What Red Flags were missed?
Internal Audit did its job but was ignored.
Actual Knowledge of corruption?
What about the DFS?
Resources
Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:
Part 1-Introduction
Part 2- The Bribery Schemes
Part 3- Overlooked Red Flags and Internal Control Failures
Part 4-Recivist Penalty
Part 5-Final Thoughts
Matt’s blog post in Radical Compliance:
Deutsche Bank Control Failures Cost $130 million
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