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. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.

Some of the issues we consider are:

  • The Bank’s compliance program was a paper program only.
  • Where was compliance?
  • What Red Flags were missed?
  • Internal Audit did its job but was ignored.
  • Actual Knowledge of corruption?
  • What about the DFS?


Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:

Part 1Introduction

Part 2The Bribery Schemes

Part 3- Overlooked Red Flags and Internal Control Failures

Part 4-Recivist Penalty

Part 5-Final Thoughts

Matt’s blog post in Radical Compliance:

Deutsche Bank Control Failures Cost $130 million