Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer

Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer

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 Learn more about your ad choices. Visit megaphone.fm/adchoices

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