The Treasury Department invites public comments on climate-related financial risks in the insurance sector. The Kitchen reviews the details of this request for information.
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Scott Moritz is Tom Fox’s guest on this episode of Looking Back at 9/11. Scott is the Senior Managing Director at FTI Consulting Risk and Investigations, assisting clients and their outside counsel in managing their response to white collar crime, misconduct and bribery incidents. He is also the host of the podcast series, Fraud Eats Strategy. Scott joins Tom to talk about how the events of 9/11 impacted the FBI.
How 9/11 Changed The FBI: Structural and Cultural Ambidexterity
9/11 fundamentally changed the FBI overnight. Scott remarks that for a long time after 9/11, the FBI was primarily focused on the attack on the Trade Center. That was the Bureau’s main investigation, and it was being worked on by all the FBI field offices, and virtually every foreign attache office in the world. Many scholars, through various organizational studies and surveys, assumed that the FBI would have created simultaneous frontline structures and processes to balance their two competing missions: national security and law enforcement. The scholars also posited that perhaps the FBI would engage in cultural ambidexterity, which would be to refuse to take on the mission of national security altogether. The FBI did something altogether unexpected and tackled both.
The Benefit of One Agency
“There was this rapid emergence of two clear, but distinct, identities, and eventually, you know, one new unified identity FBI, but some changes where, terrorism cases were centralized at headquarters…This was a big departure from the way that the FBI normally operated,” Scott tells Tom. By staying as a single agency, the FBI had better access to local law enforcement agencies and could take better advantage of defendants with information that could advance the national security mission.
A Shift In The Private Sector
Tom asks Scott to talk about any changes in the private sector he was personally involved in. The major change in the private sector post-9/11, especially with respect to financial institutions, was the induction of the Patriot Act which also paved the way for other significant changes. Financial Institutions and broker dealers had to harden the security of buildings and supply chains across the country’s infrastructure. There was also the explosion of no fly lists, watch lists and terrorist watch lists. Banks, building owners and brokerage companies had to navigate these systems often, and quickly. Scott was very involved in helping these institutions in their anti money laundering obligations, as well as their security obligations.
Looking To The Future
Tom asks Scott to share some reflections on 9/11, and for the future. Scott remarks that post-9/11, the country was more united and people were more compassionate to one another. The best of humanity in forms of kindness and outpouring of love was seen not just from Americans to each other, but from the rest of the world to America. He hopes that someday he can see that kind of love and unity again.
Resources
Scott Moritz | LinkedIn | Twitter
Fraud Eats Strategy
This week is the 20th anniversary of 9/11. On Saturday Tom and Jay ask that you take a moment of silence to remember all those who lost their lives on that day, their loved ones and those who were impacted by those events over the past 20 years.
Stories
1. Elizabeth Holmes finally goes to trial. Aly McDevitt in Compliance Week (sub req’d) Opening statements review in the WSJ.
2. The role of compliance in an ESG effort. David Povey in Compliance Week. (sub req’d) Matt Kelly weighs in on diversity as well in Navex Global’s Risk and Compliance Matters.
3. Raytheon under FCPA scrutiny. Dylan Tokar in WSJ Risk and Compliance Journal.
4. CCI surveying stress in compliance. Henry Kronk in CCI. Take the survey here.
5. From Wells Fargo to Kraft Foods. Matt Kelly in Radical Compliance. Tom and Matt in Compliance into the Weeds.
6. Has the SFO turned the corner? Martin Kenney in the FCPA Blog.
7. Measuring compliance measurement. Jeff Kaplan in COI Blog.
8. From firm specific risk to systemic risk. John Coffee in Harvard Law School Forum on Corporate Governance
9. Do you need a BOD Code of Conduct? Kristy Grant-Hart in Compliance Kristy.
10. Joe Biden-the anti-corruption President? Joe Acotoia in Corruption Crime and Compliance.
Podcasts and Events
11. On Everything Compliance, the full gang discuss where they were on 9/11 and its impact on their profession. Lisa Fine looks back on 9/11 in Great Women in Compliance.
12. On Innovation in Compliance, Tom has run a 6-part special podcast series on Looking Back on 9/11, sponsored by Affiliated Monitors. In this series he will visit with professionals from a variety of compliance perspectives who will discuss how 9/11 changed our profession, including three who were in NYC during the attacks. Hear thoughts and reflections from Gabe Hidalgo, Juan Zarate, Alex Dill, Eric Feldman, Scott Moritz and John Lee Dumas.
13. Join K2 Integrity September 15 for a round-table on the 20th Anniversary of September 11 and consider its impact on countering terrorist financing and illicit financing, and the continuing risks to national security. The roundtable will include members of the team that spearheaded the post-9/11 counter illicit finance regime: Juan Zarate, Chip Poncy, Danny McGlynn, moderated by Dr. Michele L. Malvesti. Information and Registration here.
14. Ethisphere’s World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here.
15. Breaking News features The Compliance Handbook, 2nd edition. Check out the Breaking News feature here. Purchase The Compliance Handbook, 2nd edition here.
Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Co-host Jay Rosen (AKA ‘Mr. Monitor’) can be reached at jrosen@affiliatedmonitors.com.
In today’s edition of Daily Compliance News:
- Biden Administration sues Texas. (WSJ)
- Amazon to offer tuition to employees. (Bloomberg)
- Coinbase says SEC threatened suit. (WaPo)
- Boeing BOD to face lawsuit over crashes. (BBC)
This coming Saturday is the 20th anniversary of the attacks upon America on September 11, 2001. Like most Americans, this was the seminal event in the history of our country. I have been thinking a lot about that date and the anniversary; even more so with the fall of Afghanistan and the evacuation from Kabul. I wanted to do something to commemorate this anniversary, so I decided to do a podcast series featuring the personal stories of persons in the compliance field with their thoughts about what the date of 9/11 means to them, how it changed our profession and their thoughts looking back some 20 years later. The lineup for this week is:
- 6 – Gabe Hidalgo
- 7 – Juan Zarate
- 8 – Alex Dill
- 9 – Eric Feldman
- 10 – Scott Moritz
- 11 – John Lee Dumas
I visited with Scott Moritz for my podcast series Looking Back at 9/11. Scott is now a Senior Managing Director at FTI Consulting, Inc. in their in the Global Risk & Investigations practice. On 9/11 Scott was working in midtown Manhattan. He joined me to talk about how the events of 9/11 impacted the FBI.
9/11 fundamentally changed the FBI overnight. He has some very poignant and moving recollections from that day, from realizing that many of the senior team were in the air that morning, to seeing streams of panicked New Yorkers running down the streets of Manhattan, to his journey home that night. He related how he and some colleagues were walking to Penn Station to catch a train home and as they crossed 5th Avenue, which had a view into lower Manhattan where the World Trade Center, Twin Towers had stood. As they looked down the street, they could no longer see those symbols of America’s financial center.
Scott remarked that for a long time after 9/11, the FBI was primarily focused on the attacks on the World Trade Center. That was the Bureau’s main investigation, and it was being worked on by all the FBI field offices, and virtually every foreign attaché office in the world. He discussed a Harvard Business School study which reviewed the changes made by the FBI in the wake of 9/11. Many scholars, through various organizational studies and surveys, assumed that the FBI would have created simultaneous frontline structures and processes to balance their two competing missions: national security and law enforcement. The scholars also posited that perhaps the FBI would engage in cultural ambidexterity, which would be to refuse to take on the mission of national security altogether. The FBI did something altogether unexpected and tackled both.
Moritz said, “There was this rapid emergence of two clear, but distinct, identities, and eventually, you know, one new unified identity FBI, but some changes were, terrorism cases, were centralized at headquarters… This was a big departure from the way that the FBI normally operated,”
Scott reflected that by staying as a single agency with a dual mission, one of the benefits to the FBI and to the law enforcement mission in general was the FBI had better access to local law enforcement agencies and could take better advantage of cooperating defendants who may have information that could advance the national security mission. He said, “I think that’s proven to be a really effective model. The FBI has significantly improved threat analysis following the creation of the national director of intelligence, the field intelligence group, and probably most notably the addition of embedded security analysts in each of the 56 FBI field offices.” Moreover, the most important part of the FBI’s transformation is how those intelligence analyses were effectively integrated into FBI operations. Finally, he concluded, “the FBI no longer describes itself as a law enforcement agency, although that is clearly part of the mission. Now there is a dual mission with the FBI describing itself.”
I asked Scott to reflect on changes in the private sector in which he was involved. The major change in the private sector post-9/11, especially with respect to financial institutions, was the induction of the Patriot Act which also paved the way for other significant changes. Financial Institutions and broker dealers had to harden the security of buildings and supply chains across the country’s infrastructure. There was also the explosion of no-fly lists, watch lists and terrorist watch lists. Banks, building owners and brokerage companies had to navigate these systems often, and quickly. Scott was very involved in helping these institutions in their anti-money laundering (AML) obligations, as well as their security obligations.
I asked Scott to share some reflections on 9/11, and for the future. He remarked that post-9/11, the country was more united, and people were more compassionate to one another. He spoke about “the tender mercies of strangers who were consoling one another, in the days that followed. My wife was in the grocery store and another customer was just overcome with grief, going through like this mundane task of getting groceries and a complete stranger just came up to her, hugged her and consoled her, and that was playing out all over the place. It was phenomenal, the best of human nature that really was tapped into. I also remember the outpouring of love and compassion to the American people from every part of the world. Finally, as a New Yorker, I experienced some of that outpouring firsthand.”
Moritz concluded, “I hope that we can summon some of that compassion and human kindness that followed 9/11 to heal what’s going on in our today”
Please check out this week’s podcasts on the Compliance Podcast Network, JDSupra, Innovation in Compliance, YouTube, iTunes and Spotify. Tomorrow John Lee Dumas will join me to discuss how as a college senior in ROTC on 9/11, he knew from that day forward he was going to war.
Anti-Dumping Orders
Today, the Compliance Kitchen looks at what ingredients go into a request for an administrative review of an anti-dumping or countervailing duty order.

Jay Leib is Executive Vice President of Innovation and Strategy at Reveal, an eDiscovery review company. Jay was previously the Chief Strategy Officer at kCura before he founded NexLP, a pioneering AI company in Chicago that was acquired by Reveal. He joins Vince Walden to talk about the work Reveal has been doing, and investigation and eDiscover programs.
By the year 2010, data had become much larger than human beings could get through in an efficient manner. It was for this reason that Reveal was founded, as well as to perform as an alternative to Relativity. Reveal’s mission is to help end users, law firms, in-house corporations, investigators and international consultancies “get through whatever their obligation is, as far as data goes, as fast as possible, while finding the key insights and key stories as fast as possible.”
After acquiring a company called Brain Space, Reveal created what they call an ‘AI model library.’ Their data science team has built AI models to target specific issues within data to get important documents into the hands of investigators as quickly as possible. AI models have also been built to look for issues surrounding unethical and fraudulent behaviors.
Resources
Jay Leib on LinkedIn | Twitter
NexLP.com

Eric Feldman is Tom Fox’s guest on this episode of Looking Back at 9/11. Eric is the Senior Vice President and Managing Director at Affiliated Monitors, a company that deals with monitoring large and small companies in the government contracting, construction, engineering, manufacturing, and financial services. He also conducts assessments of corporate ethics and compliance programs across many countries. Eric joins Tom to talk about the impact the events of 9/11 had on the role of Inspector General.
The Impact of 9/11 on The IG’s Role
Eric explains to Tom that 9/11 was the most informative time of his career, and the careers of many other Inspector Generals. It was a refocusing moment for everyone. Eric got to work within the oversight function, but as part of the mission he was overseeing. “That focus on mission was it for me,” he tells Tom. Eric expresses that understanding the mission helped make him a better Inspector General. IGs all over the world became more concerned with looking at the broader picture of how funds were being used at their agencies to fight the war on terror, instead of the minutiae of looking at time and attendance reporting.
The Importance of The IG Now
Tom asks Eric to elaborate on how the IG’s role rose in prominence post-9/11. Eric explains that government IGs became “part of the team” in different ways. There is more collaboration now across the agencies that IGs oversee. There is also independence: Eric expresses that there must be a balance between collaboration and independence. IGs are especially important as they ensure that the dollars being spent on the war and mission are being spent properly.
A Wake Up Call of Unity
Eric reflects that 9/11 was a wake-up call for the United States. The country came together, and there was a level of unity and patriotism, as well as a sense of duty that overtook politics. Eric hopes that the people can return to that unity without another catastrophe.
Resources
Eric Feldman | LinkedIn | Twitter
Affiliated Monitors
Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Matt Kelly, Jonathan Marks, Mike Volkov, Jonathan Armstrong and Jay Rosen episode dedicated as our collective reflections on the 20thanniversary of 9/11. We end with a veritable mélange of shouts outs and one epic rant.
1. Mike Volkov has a melancholy shout out for the US soldiers killed in the recent bombing in Kabul who were not yet born or very young children on 9/11.
2. Jonathan Marks shouts out to the first responders of 9/11 and the men and women of the US military.
3. Jay Rosen shouts to civility and unity, lost commodities in 2021 America and hopes we can reclaim those qualities that brought us together after 9/11.
4. Matt Kelly has an epic rant on backsliders in politics and society that are running away from what America stands for.
5. Jonathan Armstrong shouts out to all those first responders who run towards the danger and to Dr. Peter Holden and his colleagues who treated bombing victims on 7/7 in London.
6. Tom Fox shouts out to men and women of the US military who went to war some 20 years ago when they were in the late teens and early 20s. He also shouts out to Iraq veteran John Lee Dumas who reminds us all that we are the Land of the Free because of the Brave.
Additional Resources:
For more reflections on 9/11, check out my podcast series, Looking Back on 9/11. The full schedule is:
Sept. 6-Gabe Hidalgo
Sept. 7-Juan Zarate
Sept. 8-Alex Dill
Sept. 9-Eric Feldman
Sept. 10-Scott Moritz
Sept.11-John Lee Dumas
The podcasts will post at midnight on iTunes, YouTube, Megaphone and Spotify. It will post at 6 AM on the Compliance Podcast Network and JDSupra.
The members of the Everything Compliance are:
• Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
• Mike Volkov – One of the top compliance commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com
• Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
• Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com
• Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at jonathan.marks@bakertilly.com
The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.
In today’s edition of Daily Compliance News:
- MarshMac gets dedicated CCO. (WSJ)
- Texas anti-abortion law to cost state millions. (Bloomberg)
- Opening statements in Elizabeth Holmes trial. (WSJ)
- Silicon Valley culture on trial. (FT)