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 go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective.

Some of the highlights include:

  • What does this enforcement action tell up about internal controls?
  • How were the business units able to evade internal controls for so long?
  • Was there control override?
  • What is the role of ERP systems such as Oracle and SAP in compliance?
  • If a company refuses to use standard ERP systems, is that a control failure under the FCPA?
  • What are the lessons learned for a corporate compliance program?
  • What does all this mean for compliance professionals going forward?


Tom’s blog posts, both the FCPA Compliance and Ethics Blog.

Part 1-Overview

Part 2-The Bribery Schemes