Tag: fraud

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Red Flags Rising

Red Flags Rising: S01 E47: David Metcalf, U.S. Attorney for the Eastern District of Pennsylvania

Mike and Brent welcome to the podcast the U.S. Attorney for the Eastern District of Pennsylvania, David Metcalf.

They discuss the U.S. Attorney’s background working as a government lawyer, a lawyer in private practice, and an in-house lawyer at a large company, and what perspectives that varied background has given him (01:42); the potential pitfalls of over-reliance on legal privilege, especially for company employees (09:00); the relevance of the Japanese classic film Rashomon (1950) to investigations and compliance, especially in terms of mooting various perspectives when making decisions where “knowledge” or “willfulness” is relevant (11:06); the important mission and objectives of the U.S. Department of Justice’s (DOJ’s) new National Fraud Enforcement Division (NFED) (13:07); how the U.S. Attorney sees trade and export or import enforcement unfolding nationally and in the Eastern District of Pennsylvania (19:46); the importance of frameworks and tools, such as Brent’s Fraud Four-Circle Framework to identifying and effectively responding to potential issues (23:53); the importance to the DOJ of voluntary disclosures and the incentives being offered to corporations today (26:56); and the broader work of the Eastern District of Pennsylvania, including how they develop and how people can report cases (33:07). They then conclude with the latest edition of Brent’s “Managing Up” segment (34:31).

More about U.S. Attorney David Metcalf

The Eastern District of Pennsylvania’s White Collar Justice Program

The DOJ’s National Fraud Enforcement Division

More about the 1950 classic Japanese film “Rashomon”

Contact Brent: brent@redflagsrising.com

More about Brent

Connect with Brent on LinkedIn

Contact Mike: michael.huneke@morganlewis.com

More about Mike

Connect with Mike on LinkedIn

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Daily Compliance News

Daily Compliance News: October 15, 2026, The Not a Lawyer Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we cover four stories from the business world, compliance, ethics, risk management, leadership, or general interest for compliance professionals.

Top stories include:

  • How super-AI users are reimagining work. (FT)
  • Fraud allegations at NATO. (AP News)
  • New White House Press Secretary never took the bar exam. (WSJ)
  • What do AI agents talk about at dinner parties? (NYT)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

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Compliance Into the Weeds

Compliance into the Weeds: Amex AML Enforcement: Credit Card Risk, SAR Failures, and Board Accountability

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance topics, literally going into the weeds. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against American Express.

The penalties included a $350 million civil penalty, cease-and-desist orders, and extensive compliance obligations tied to weaknesses in customer due diligence, suspicious activity reporting, staffing, and risk assessment. Tom highlighted that Amex processed billions of transactions, many ordinary credit-card transactions, showing banks must know all customers, not just high-dollar activity, and noted regulators’ broader pattern of similar actions across the industry as financial innovation outpaced compliance investment.

Matt noted that regulators depend on SARs as critical inputs for broader enforcement “mosaics,” explaining why SAR failures draw intense scrutiny. The orders’ notable feature is direct board involvement, requiring a board-level compliance committee and action plan to hold management accountable, with a strong focus on end-to-end documentation and evidence trails; they see no facts suggesting the egregious, employee-involved criminality seen in TD Bank.

Key highlights:

  • Industry Pattern and Root Causes
  • Innovation as Compliance Risk
  • Board Oversight Mandates
  • Why SARs Matter
  • DOJ Risk and TD Bank Comparison
  • Disjointed Compliance and Fixes

Resources:

Tom in the FCPA Compliance Report, Part 1 and Part 2

Tom

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A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.

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Daily Compliance News

Daily Compliance News: October 2, 2026, The Wither Capitalism Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • How badly did Man City fraud distort the Premier League? (Reuters)
  • How high-risk is Venezuela? (WSJ)
  • Is capitalism in danger? (FT)
  • Insider knowledge of a pre-emptive pardon. (NYT)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

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Daily Compliance News

Daily Compliance News: August 17, 2026, The States Combatting Federal Corruption Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • 4 things states can do to combat federal corruption. (JustSecurity)
  • Fury now greater at health care execs. (NYT)
  • Former Tricolor CEO must face criminal charges. (Reuters)
  • JPMorgan de-banks Polymarket. (WSJ)

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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Compliance Into the Weeds

Compliance into the Weeds: OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it in greater depth. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action fining FTI Consulting $1.05 million for a sanctions violation involving indirect dealings with Russia’s state-owned VTB Bank.

FTI provided economic analysis for VTB in litigation, but, knowing VTB was sanctioned, used a law firm as an intermediary to invoice and receive payment, which OFAC said does not avoid liability because prohibitions apply to indirect transactions as well as direct ones. OFAC doubled the base penalty of $525,000 explicitly to promote future compliance by similarly situated companies, signaling strong disapproval of “middleman” structures. The case also involved unpaid invoices that became an impermissible extension of credit to a sanctioned entity, highlighting the need for rigorous contract and payment-term review beyond basic sanctions screening and for dedicated sanctions expertise.

Key highlights:

  • Introducing the OFAC Case
  • Middleman Billing Scheme
  • Why Screening Misses Indirect Risk
  • Did Compliance Approve It?
  • OFAC Expectations and Capability
  • Penalty Doubled Warning Shot
  • Unpaid Invoices as Credit Extension

Resources:

Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards, all for podcast excellence.

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Daily Compliance News

Daily Compliance News: June 17, 2026, The Book-Cation Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • AI compliance failures. (TechRepublic)
  • Sounds like heaven. (NYT)
  • Brendan Sorsby is now the NFL’s problem. (WSJ)
  • Did JLR hide fire risks in its cars? (FT)

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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Daily Compliance News

Daily Compliance News: May 15, 2026, The Adani Walks Free Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Nigerian ex-oil minister gets 75 years for corruption. (Reuters)
  • Adani pledges $10bn and gets a free pass. (NYT)
  • Commit fraud, self-report, and walk free in SDNY. (FT)
  • The US makes more corruption claims against Mexico. (The Guardian)

For more information on the use of AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on Amazon.com.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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Great Women in Compliance

Great Women in Compliance: DOJ’s New Fraud Division: Practical Insights for Compliance Professionals

In this episode, Lisa and Ellen speak with Leigha Simonton and Jennifer Beidel, former prosecutors and now partners at Dykema Gossett. They discuss the changes in the U.S. Department of Justice, focusing on the National Fraud Enforcement Division and shifts in enforcement priorities.

They discuss the spotlight on fraud involving federal funds, especially in healthcare, PPP loans, and other government programs. They discuss the new structure of the criminal fraud division and how that may change the government’s approach to prosecuting cases. At the same time, they also note that many experienced prosecutors and agents have left the DOJ, creating a gap between stated priorities and capacity and expertise.

Leigha and Jennifer also provide practical guidance for ethics and compliance professionals. They confirm that a risk assessment is critical and that any company that received federal funds, such as PPP loans, should remain vigilant for possible exposure under the current enforcement trends.

Even with these changes, they reiterate that effective, well-tested compliance programs do matter if the U.S. government is considering (or engaging in) prosecution. A proactive program—not the tick-the-box type—demonstrates implementation and remediation, increasing the likelihood of a declination.

This is a great episode for those of us trying to understand the US DOJ’s current enforcement landscape amid uncertainty.

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Great Women in Compliance

Great Women in Compliance: Pretty in Pink: Inside the World of Women Fraudsters

Listen in to hear from two renowned fraud experts, Kelly Paxton & Professor Kelly Richmond Pope, talk about pink collar crime:

  • What is it
  • Why it happens
  • How to spot it and
  • What we can do to stop it 

With our guests, Sarah Hadden and Ellen M. Hunt, explore whether there are differences between women and men fraudsters, what tools are available or may become available in the future to detect fraud before it happens, and whether biases or preconceived stereotypes hinder our ability to prevent and identify pink-collar crime.  

Hear from two of the most experienced fraud professionals by tuning in on your favorite podcast platform, on Corporate Compliance Insights, and the Compliance Podcast Network.