Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer

Compliance into the Weeds

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

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