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
