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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 16 – Effective and Tailored Compliance Training

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be 6-8 minutes short, with three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In today’s episode, we delve into the evolution and importance of employee compliance training, focusing on fostering a culture of compliance within organizations. We discuss key guidelines from the FCPA Resource Guide 2nd Edition and subsequent updates from the DOJ and SEC, emphasizing the necessity of effectively communicating and tailoring training programs to an organization’s specific audience. Critical aspects include the importance of training in local languages, assessing the risk profile of employees, and ensuring senior management’s participation. Furthermore, we explore the concept of ‘espresso shots’ or concise training segments to enhance learning and retention. Metrics such as increased hotline use and survey feedback are essential for evaluating the effectiveness of compliance programs.

Key highlights:

  • Evolution of Compliance Training Standards
  • Measuring Training Effectiveness
  • Tailoring Training to Audience Needs

Resources:

Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast.

Categories
Pawtastic Friends - The Paw Talk

Pawtastic Friends: The Paw Talk – Luca, Artemis and Otto

Welcome to Pawtastic Friends-The Paw Talk. In this podcast, host Tom Fox will visit with Michael and Melissa Novelli, co-founders of Pawtastic Friends and those who work with them at Pawtastic Friends. Michael and Melissa are dedicated to helping shelter and rescue dogs in the Las Vegas area become more adaptable through enrichment training, activities such as yoga and aquatics training, obedience, and agility. This podcast is sure to tug on your heartstrings; just listen to how sweet this one dog is! Tune in to hear more from Michael and Melissa Novelli as they discuss their passion for helping needy pups. Get ready for an exciting episode of Pawtastic Friends – The Paw Talk! In this episode, we feature Luca, Artemis, and Otto.

Michael and Melissa are advocates for animal welfare and the driving forces behind the Jordan’s Way fundraiser, a pivotal event that ensures the financial viability of their rescue center. Michael views the fundraiser as an opportunity to rally community support, organizing engaging activities like games and challenges to help reach their ambitious $25,000 goal. Melissa shares this enthusiasm, emphasizing the fundraiser’s critical role in covering operational costs and the potential impact of businesses matching donations. Both are committed to the broader mission of animal rescue, with Melissa’s Foster Initiative Project highlighting the need for compassionate foster homes to transform the lives of dogs like Luca and Artemis.

Quotes

“Sometimes different is good.” – Melissa Novelli

“That’s what this center was built for—for those moments when you can help change lives.” – Michael Novelli

It was such a transformation when I was watching on the camera and I saw this dog become everything he could be. I was like, wow, you know, Michael.” – Melissa Novelli

Resources:

Pawtastic Friends

Donate to Pawtastic Friends

Pawtastic Friends on Instagram

Pawtastic Friends on Facebook

Jordan’s Way US Tour

Jordan’s Way visit to Pawtastic Friend’s in Las Vegas

Categories
Everything Compliance

Everything Compliance: Episode 147, The Welcome to 2025 Edition

Welcome to this edition of the award-winning Everything Compliance. In this episode, Matt Kelly, Jonathan Armstrong, Karen Woody, and Karen Moore examine various issues for compliance professionals under the incoming Administration.

a. Jonathan Armstrong takes a lesson on business ethics from handbags in South Korea, and we learn about ‘Say-Do.’ He rants about Liz Truss trying to salvage her name through litigation.

b. Karen Moore deeply dives into some interesting litigation around pregnancy discrimination claims, and we learn about ‘stray remarks.’ She rants about Meta dropping its fact-checking and shouts out former President Jimmy Carter.

c. Matt Kelly considers the Bayview Asset Management enforcement action and what it may mean for compliance. He shouts out to Steve Guttenberg and all those Los Angelinos who assist during the ongoing fires. .

d. Karen Woody looks at what the new Trump Administration may mean for the CFPB going forward. She rants about the idiots denying climate change.

e. Tom Fox shouts out to two brothers in arms: former Presidents Gerald Ford and Jimmy Carter. Their love for each other and Gerald Ford’s tribute to Jimmy Carter, read by Gerald’s son, Steven Ford, at Jimmy Carter’s funeral.

The members of the Everything Compliance are:

The host and producer, rantor (and sometime panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the award-winning Compliance Podcast Network.

For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here.

Check out the full 3-book series, The Compliance Kids on Amazon.com.

Categories
Daily Compliance News

Daily Compliance News: January 16, 2025 – The SEC Sues Musk (Again) Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • What is forced labor? (BBC)
  • Is China aiming to sell TikTok to Musk? (NYT)
  • KPMG will open a US law firm in AZ. (Reuters)
  • SEC sues Elon Musk yet again, this time over Twitter purchase. (Bloomberg)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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Rotary Voices of Kerrville

Rotary Voices of Kerrville – Jeff Wendling on Stewardship and Leadership

Welcome to Rotary Voices of Kerrville, the podcast series that shines a spotlight on the Rotary Club of Kerrville, Texas—a club with a rich community service, leadership, and dedication history. For nearly 100 years, the Rotary Club of Kerrville has been at the heart of initiatives that make a real difference locally and globally. Through this podcast, we’ll explore the club’s incredible projects, hear from its inspiring members, and learn about the values driving their commitment to “Service Above Self.” In this episode, host Tom Fox speaks with Jeff Wendling, immediate past president of the Kerrville Rotary Club, to discuss his journey and experiences within the organization.

Jeff shares his initial involvement with Rotary in 2008, his leadership roles, and his perspectives on stewardship in organizational settings. He highlights the club’s numerous community-focused events, including the First Responders Award Luncheon and Blue Santa. Jeff also touches on significant initiatives such as fundraising for polio vaccines, youth engagement programs, and upcoming plans for the club’s 100th anniversary in 2026. This episode offers valuable insights into the impact of community service and leadership in fostering local and global change.

Highlights include:

  • Getting Involved with Rotary
  • Leadership Journey in Rotary
  • Role as President and Stewardship
  • First Responders Luncheon and Community Impact
  • 100th Year Anniversary Plans
  • Community Partnerships and Networking

Resources:

Rotary Club of Kerrville

Rotary District 5840

Rotary International

Categories
Blog

Overcoming AI Resistance for Corporate Compliance Professionals

Artificial intelligence (AI) presents a paradox for corporate leaders. On one hand, its potential is undeniable: in a 2023 Gartner survey, 79% of corporate strategists deemed AI, automation, and analytics critical to their success. Yet, only 20% actively use AI in their daily activities. The gap between intention and action speaks volumes, especially in compliance, where AI offers unprecedented opportunities to manage risk, enhance efficiency, and ensure adherence to regulations. In a recent Harvard Business Review Article entitled Why People Resist Embracing AI, Julian De Freitas reviewed this issue and provided some ways to think through how to respond.

Despite its promise, AI adoption is hindered by human skepticism. Concerns range from fears of job loss to distrust in AI’s capacity for ethical decision-making. For compliance professionals, understanding and addressing these barriers is vital for leveraging AI to strengthen compliance programs and drive corporate integrity. In this blog post, I want to explore these challenges and how compliance leaders can overcome them. I have adapted Freitas’ article for the compliance professional.

The Five Barriers to AI Adoption in Compliance

  • AI’s Opacity: The “Black Box” Problem

Many employees resist AI because it operates as an inscrutable “black box,” offering conclusions without clear explanations. This lack of transparency can be a deal-breaker for compliance teams, as accountability is paramount in regulatory environments. How can an algorithm flag a suspicious transaction or identify potential bribery risks without explaining its rationale?

Compliance leaders should prioritize AI tools that offer clear, comparative explanations to overcome this barrier. For instance, instead of stating that a third-party transaction was flagged as high risk, the system should explain why, perhaps because of discrepancies in invoice patterns or connections to sanctioned entities. Such insights enhance trust and empower teams to make informed decisions.

Start small. Introducing simpler AI models before scaling to more complex ones can build confidence. Much like Miroglio Fashion’s approach to demand forecasting, a pilot program allows teams to familiarize themselves with AI and see its benefits before adopting more advanced systems.

  • AI Is Perceived as Emotionless

Compliance often involves navigating complex, human-centric issues, such as whistleblower reports, triage, Institutional Justice/Fairness, or ethical dilemmas. Many employees doubt AI’s ability to handle such subjective tasks, viewing it as emotionless and rigid. While AI can process vast amounts of data, can it understand the nuances of a whistleblower’s complaint or the subtleties of cultural differences in compliance?

Here, framing matters. Compliance leaders should emphasize AI’s ability to provide objective insights while leaving subjective decision-making to human professionals. For instance, AI can flag patterns in expense reports suggesting potential fraud, but the decision to investigate remains with compliance officers.

Anthropomorphizing AI tools can also make them more relatable. Tools like Amazon Alexa, with humanlike names and voices, have shown that users are more willing to interact with AI when it feels approachable. However, tread carefully in sensitive contexts, such as investigations, where a less personalized AI may feel less intrusive. Always remember the Human-in-the-Loop.

  • AI’s Perceived Rigidity

A common misconception about AI is that it cannot adapt or evolve. For compliance professionals, this rigidity could mean AI systems are seen as inflexible, unable to account for unique organizational contexts or evolving regulatory landscapes.

To address this, emphasize AI’s learning capabilities. Tools that improve over time, such as those that adapt to new fraud schemes or regulatory updates, mainly through large language models, can demonstrate AI’s ability to evolve alongside the business. Netflix’s content recommendations, for example, continuously improve based on user behavior. Compliance systems should follow suit, showcasing how AI refines its processes to meet organizational needs better.

At the same time, compliance leaders must balance flexibility with predictability. Highly adaptable AI systems can introduce risks if they deviate too far from expected outcomes. Regular monitoring and safeguards are critical to ensure the system operates within defined ethical and regulatory boundaries.

  • Fear of Loss of Control

AI’s autonomy often feels threatening, particularly in compliance, where human judgment is paramount. Employees may worry that AI will override their expertise or act independently in ways that could jeopardize compliance efforts. For example, an AI tool autonomously approving transactions without human review might lead to unchecked risks.

The solution? Implement human-in-the-loop systems, where AI supports decision-making rather than replaces it. Nest’s smart thermostat, which allows users to switch between manual control and automation, is an excellent analogy. In compliance, this could mean using AI to flag risks while leaving final decisions to compliance officers. Such hybrid models restore employees’ sense of agency while ensuring AI enhances rather than undermines human oversight.

  • Preference for Human Interaction

Compliance is inherently relational. Building trust, navigating cultural differences, and addressing employee concerns require human empathy—qualities many believe AI lacks. Resistance to AI often stems from the belief that humans are better equipped to handle nuanced interpersonal issues.

While AI cannot replicate human empathy, it can support human efforts. For example, generative AI can analyze patterns in hotline reports to identify systemic issues, allowing compliance officers to focus on building relationships and fostering a speak-up culture. Framing AI as a tool that amplifies human capabilities rather than replacing them can help reduce resistance.

Strategies for Driving AI Adoption in Compliance

  1. Start with Transparency. Be upfront about what AI can and cannot do. Educate employees on how AI systems work, their limitations, and the safeguards to prevent misuse. Transparency builds trust and encourages collaboration.
  2. Focus on Small Wins. Demonstrating tangible benefits through pilot programs can win over skeptics. For instance, AI can automate low-risk tasks like policy distribution or routine transaction monitoring. Success in these areas can pave the way for broader adoption.
  3. Prioritize Training and Support. AI adoption requires investment in employee training. Equip teams with the skills to use AI tools effectively and provide ongoing support to address questions or concerns. Mercedes-Benz’s Turn2Learn initiative offers extensive AI training and is a model worth emulating.
  4. Align AI with Ethical Standards. Compliance professionals must ensure AI systems align with the organization’s values and ethical standards. Regular audits, bias checks, and transparent reporting can reassure stakeholders that AI is being used responsibly.
  5. Measure and Iterate. Establish clear metrics to evaluate AI’s impact on compliance processes. Use these insights to refine the system, addressing pain points and enhancing effectiveness.

AI in Compliance: A Strategic Imperative 

AI’s potential to revolutionize compliance is immense. From automating routine tasks to identifying emerging risks, it can make programs more efficient, proactive, and resilient. However, realizing this potential requires more than technology; it demands a cultural shift.

Compliance leaders must champion AI adoption by addressing psychological barriers and demonstrating its value. Organizations can harness AI to strengthen compliance and drive business success by prioritizing transparency, fostering trust, and empowering employees. As the Gartner survey reminds us, AI is not just a tool for the future—it’s a strategic imperative for today. The question isn’t whether to adopt AI but how to do so in a way that aligns with organizational goals and values. For compliance professionals, the path forward is clear: embrace AI, empower your teams, and lead the charge toward a more efficient, ethical, and innovative compliance landscape.