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?

Resources
Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:
Part 1–Introduction
Part 2– The 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