With Jay on a holiday assignment, Tom is joined by Professor Karen Woody to look at some of the week’s top compliance and ethics stories this week in the Naughty List edition.


  1. JPMorgan tagged $200MM for failures in electronic record keeping. Tom in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Tom and Matt in Compliance into the Weeds.  
  2. Nikola was fined $125MM for the former CEO’s imprudent tweets. Tom in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Jaclyn Jaeger in Compliance Week(sub req’d).
  3. SOX 20 years later. Michael Peregrine looks back at the upcoming 20th anniversary of Sarbanes-Oxley in the Harvard Law School Forum on Corporate Governance
  4. France is updating its ABC regime. Frederick Davis in GAB.   
  5. Another Unaoil defendant appeals conviction based upon SFO misconduct. Dylan Tokar in WSJ Risk and Compliance Journal.
  6. What happened to FCPA Compliance in 2021? Dick Cassin explores in the FCPA Blog.  
  7. The story of internal controls and Netflix? Jonathan Marks in BakerTilly.  
  8. Vietnam imposes a 14-year sentence for wildlife trafficking. Jon Rusch in Dipping Through Geometries
  9. Lawyers and ESG. Lawrence Heim in PracticalESG
  10. Prioritizing your policy updates. David Banks in Risk and Compliance Matters.

Podcasts and Events

  1. Want some fun over the holidays? Join Tom and One Stone Creative co-founder Megan Dougherty to explore the full MCU. In Episode 1, Captain America. In Episode 2, Captain Marvel. Next week in Episode 3, Iron Man.  
  2. In December on The Compliance Life, I visited with Matt Silverman, Director of Trade Compliance at VIAVI. Matt is the first Trade Compliance Director I have hosted on TCL. In Part 1, Matt details his academic career and early professional life. In Part 2, Matt moves into trade compliance. In Part 3, Matt moves into the Director’s chair. 
  3. The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Classroom Insider. In this unique pod, Karen interviews some of her students to tell them the history of insider trading. Check out Episode 1 on  Episode 2, the disclosure or abstain rule. In Episode 3 (premiering Dec. 31), they will take up narrowing the scope of the disclose or abstain rule. 
  4. The Shout Outs and Rants of Everything Compliance gets its own iTunes show. Everything Compliance has its first-year end review episode. 
  5. On Hidden Traffic, Gwen Hassan hosts Andrew Wallis, head of Unseen UK.

Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Karen Woody is a Professor of Law at Washington and Lee. She can be reached at kwoody@wlu.edu.