Tag: Citibank

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Compliance Into the Weeds

Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer

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. This week Matt and Tom take a deep dive into one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.

Some of the issues we consider are:

·      How did this Fubar occur?

·      What was the role of complexity?

·      Why did the employees make this mistake?

·      What about training?

·      Where were internal controls?

·      What is the ‘value for discharge’ defense?

·      Does this all just come down to finders keepers?

·      What are the compliance lessons? 

Resources

Tom’s blog posts on the FCPA Compliance and Ethics Blog:

Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 – The Facts
Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned 
The Citibank decision

Categories
Compliance Into the Weeds

Citibank Failures in Risk Management

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 and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management process. Some of the issues we consider are:

·      Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance.

·      How the OCC Order is an audit road map.

·      What does that mean for compliance on the Board?

·      Did the OCC push out Michael Corbat?

·      Focus on the ERM Blueprint.  

Resources

See Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program