Compliance into the Weeds: Episode 102- a Rumination on Substantial Involvement

Thomas Fox - Compliance Evangelist
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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 and I take a deep dive into Michael Cohen’s guilty plea and DAG Rod Rosenstein’s ‘substantially responsible” amending of the Yates Memo. Since Cohen said in the plea agreement that he only lied to Congress to support what he believed Trump wanted, not at Trump’s direction, it gives us the opportunity to explore a gray area about See more +
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 and I take a deep dive into Michael Cohen’s guilty plea and DAG Rod Rosenstein’s ‘substantially responsible” amending of the Yates Memo. Since Cohen said in the plea agreement that he only lied to Congress to support what he believed Trump wanted, not at Trump’s direction, it gives us the opportunity to explore a gray area about accountability for senior execs complicit in misconduct, but not substantially responsible for it. It provides several new lessons learned for the compliance professional (and some old ones as well). See less -
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