Compliance into the Weeds: Episode 102- a Rumination on Substantial Involvement

Compliance into the Weeds: Episode 102- a Rumination on Substantial Involvement

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. In this episode, Matt Kelly and I take a deep dive Michael Cohen’s guilty plea and DAG Rod Rosenstein’s ‘substantially responsible” amending of the Yates Memo. Since Cohen said in the plea agreement that he only lied to Congress to support what he believed Trump wanted; not at Trump’s direction. It gives us the opportunity to explore a gray area about accountability for senior execs complicit in misconduct or to use Rosenstein's language have 'substantial involvement' but not substantially responsible for it. It provides several new lessons learned for the compliance professional (and some old ones as well). Some of the highlights from this podcast are: What does ‘substantially involved in or responsible for the misconduct’ actually mean?What does ‘substantially involved in or responsible for the misconduct’ actually mean?If the voting public, and employees; don’t see justice served, for legal distinctions they may neither appreciate nor care about, that’s going to blunt their interest in talk about ethical conduct; will it will corrode the trust they have in organizations?What if the senior executives are complicit in the misconduct by fostering a poor control environment; and yet they personally were not substantially involved in the misconduct?Will this drive up the importance of strong governance? For example, where were the auditors, inspecting the control environment? Or would this lead to shareholder lawsuits against the board?How would the Justice Department apply the Rosenstein policy to those circumstances?What were the key lessons learned for the compliance practitioner? Learn more about your ad choices. Visit megaphone.fm/adchoices

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Episoder(434)

Survey Finds Widespread Retaliation Against Compliance Officers

Survey Finds Widespread Retaliation Against Compliance Officers

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 f...

1 Jul 26min

Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

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 fo...

24 Jun 27min

OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank

OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank

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 fo...

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Why the Compliance Job Market Feels Frozen

Why the Compliance Job Market Feels Frozen

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 fo...

3 Jun 23min

An SEC Rollback and a Tribute to Barney Frank

An SEC Rollback and a Tribute to Barney Frank

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...

27 Mai 23min

The DOJ Trainwreck and the Rising Risk Calculus for Compliance and Self-Disclosure

The DOJ Trainwreck and the Rising Risk Calculus for Compliance and Self-Disclosure

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...

13 Mai 26min

Ohio State and Improper Requests by a President

Ohio State and Improper Requests by a President

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 the subject more fully. Looking...

6 Mai 23min

Navigating DOJ's Evolving Self-Disclosure Strategies

Navigating DOJ's Evolving Self-Disclosure Strategies

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 the subject more fully. Looking...

29 Apr 23min

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