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