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 Learn more about your ad choices. Visit megaphone.fm/adchoices

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What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance.