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Compliance Into the Weeds

Compliance into the Weeds: Of Fat Fingers, Internal Controls and Compliance

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 more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom and Matt delve deep into Citigroup’s $126 million trading error, resulting from poor internal controls.

They discuss how a simple ‘fat finger’ error by a trader led to a major flash crash on European stock exchanges in 2022, and how the failure of Citigroup’s internal controls allowed it to happen. The discussion covers multiple compliance lessons, including the importance of understanding the human element in control design, the need for adequate staffing and monitoring, and the necessity of consistent global risk management.

Fox and Kelly also highlight the importance of addressing findings from internal audits and maintaining urgency in improving internal controls. They emphasize that companies should think creatively about risk management, taking into account various global factors, including holidays and local regulations.

Key Highlights:

  • The Citigroup Internal Control Fiasco
  • Compliance Lessons from Citigroup’s Mistake
  • The Human Element in Compliance and Control Failures
  • Global Consistency in Risk Management

Resources:

Matt on Radical Compliance

 Tom 

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Compliance Into the Weeds

Compliance into the Weeds: Episode 114-Lessons on Internal Control Overrides

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 Kelly (the coolest guy in compliance) and I take a deep dive into the recent Bankrate DOJ enforcement action in which the company garnered a NPA and for which it paid a total penalty of $28.5 million. We feature a discussion of internal control overrides.

Some of the highlights include:

  • What are the background facts of the matter?
  • Why should you never name a slush fund “Ed’s Cushion?
  • What is the difference between management over-ride of internal controls and abuse of management control override?
  • Why is robust accounting required when there is a single source of data?
  • What is the straight line from internal controls and accounting to the Board and the audit committee?
  • Where was the Audit Committee?

For additional reading see Matt’s blog post Bankrate pays $28.5 million in fraud case on Radical Compliance.