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

Denne episoden er hentet fra en åpen RSS-feed og er ikke publisert av Podme. Den kan derfor inneholde annonser.

Episoder(446)

New Fraud Section Guidelines

New Fraud Section Guidelines

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for har...

7 Okt 24min

Southern Glazer’s NPA: How Remediation and ECCP Alignment Drove a Favorable Settlement

Southern Glazer’s NPA: How Remediation and ECCP Alignment Drove a Favorable Settlement

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Look...

30 Sep 21min

Whistleblower Resolution Delays Is Justice Denied

Whistleblower Resolution Delays Is Justice Denied

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Look...

23 Sep 20min

Governing Agentic AI: DFS Cyber Risk Assessments, EU AI Act Accountability, and the Inventory Problem

Governing Agentic AI: DFS Cyber Risk Assessments, EU AI Act Accountability, and the Inventory Problem

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them fully and uncover hard-hitt...

16 Sep 27min

 Clippers Salary-Cap Circumvention: Sham Endorsements, Contract Red Flags, and Compliance Lessons

Clippers Salary-Cap Circumvention: Sham Endorsements, Contract Red Flags, and Compliance Lessons

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Look...

9 Sep 34min

Broken Execution in Day-to-Day Compliance Operations – The BAE Enforcement Action

Broken Execution in Day-to-Day Compliance Operations – The BAE Enforcement Action

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Look...

2 Sep 22min

AI for Compliance: Lessons from Teaching Cohorts⁠

AI for Compliance: Lessons from Teaching Cohorts⁠

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for som...

26 Aug 24min

Compliance Implications of DOJ’s New Fraud Division and McDonald Memo

Compliance Implications of DOJ’s New Fraud Division and McDonald Memo

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them in greater depth and uncove...

19 Aug 24min

Populært innen Business og økonomi

stopp-verden
dine-penger-pengeradet
rss-penger-polser-og-politikk
e24-podden
rss-borsmorgen-okonominyhetene
rss-skravla-gar
rss-pa-konto
livet-pa-veien-med-jan-erik-larssen
tid-er-penger-en-podcast-med-peter-warren
rss-orjasater
pengepodden-2
finansredaksjonen
lederpodden
utbytte
morgenkaffen-med-finansavisen
stormkast-med-valebrokk-stordalen
liberal-halvtime
rss-markedspuls-2
okonomiamatorene
rss-fa-makro