Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer - a podcast by Tom Fox

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

Further episodes of Compliance into the Weeds

Further podcasts by Tom Fox

Website of Tom Fox