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Compliance Tip of the Day

Compliance Tip of the Day – Building a Data-Driven Culture

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, we aim to provide bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Today, we review how compliance can drive a data-driven culture in the compliance function and throughout the organization.

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

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The Ethics Experts

Episode 196 – Laura Sauber

In this episode of The Ethics Experts, Nick welcomes Laura Sauber.

Laura Sauber is the CEO of Sauber Consulting, a firm dedicated to helping healthcare organizations build cultures where ethics and compliance risks are proactively prevented, identified, and resolved—ensuring they do not impede the organization’s strategic objectives.

Laura is recognized not only as a strategic compliance leader but also for her strong business acumen, innovative approach, and collaborative leadership style. Passionate about driving organizational integrity and performance, Laura excels at advising leaders and cross-functional teams on effectively navigating the complex federal and state regulatory landscape and improving and sustaining organizational performance.

https://www.linkedin.com/in/laura-sauber

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Riskology

Riskology by Infortal™: Episode 41 – Avocado Toast & Geopolitical Risk

On January 20th, the President signed an Executive Order focused on designating cartels as foreign terrorist organizations.

This decision could reverberate throughout industries, requiring companies to adapt their approach to due diligence conducted on customers, clients, and suppliers. Third-party risk management teams must consider a heightened regulatory and criminal enforcement environment.

Tune in to Riskology by Infortal™ Episode 41, where hosts Dr. Ian Oxnevad and Chris Mason break down the potential impact of designating cartels as terrorist organizations. 

Executive Order and Its Ripple Effect

Chris Mason emphasizes how “the stakes will be raised… both from a reputational standpoint and a criminal standpoint.”

The designation of cartels as terrorist entities could fundamentally shift how businesses operate across the US-Mexico border. Tighter constraints, impacting banks, suppliers, and a wide range of industries, could have a chilling effect as businesses work to adapt their compliance programs to account for exposure to a new regulatory framework.

In-house counsel must also ensure that policies and procedures align with any emerging regulatory or legislative changes.

Cartel Influence on Legitimate Industries

Dr. Ian Oxnevad further illustrates the pervasive reach of cartels into legitimate sectors, using the avocado supply chain as a prime example. Businesses dealing with seemingly innocuous products must now consider the potential risk of indirect association with terrorist networks.

Key Takeaways

  • Heightened Regulatory Scrutiny: Classifying cartels as terrorist organizations will dramatically increase regulatory pressures on businesses with ties to Mexico, necessitating robust compliance strategies.
  • Increased Vigilance: Companies operating in financial services, agriculture, and logistics must implement enhanced vetting policies and procedures to account for changes.
  • Due Diligence Imperative: Updated enhanced due diligence procedures are critical across all regional business sectors to avoid reputational damage and possibly criminal prosecution.
  • Broader Implications for International Trade: This classification could further strain U.S.-Mexico relations and complicate trade logistics, requiring businesses to adapt swiftly and strategically.

For more insights, tune into Episode 41 of Riskology by Infortal.™

Resources:

Infortal Worldwide

Email

Dr. Ian Oxnevad on LinkedIn

Chris Mason on LinkedIn

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Corruption, Crime and Compliance

Family International and Owner Pay $1.07 Million to Settle Violations of Russia Sanctions Program

How do sanctioned Russian oligarchs continue to move their wealth despite international restrictions? The answer lies in real estate, shell companies, and complicit gatekeepers. In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into one of the latest OFAC enforcement actions against Family International and its owner, Roman Sinyavsky, for facilitating sanctions evasion on behalf of Russian oligarchs. Through complex real estate transactions, Sinyavsky helped conceal luxury properties owned by Valeri Abramov and Viktor Perevalov, allowing them to continue generating revenue despite U.S. sanctions. This case highlights the growing risk of financial crime in the real estate sector and the increasing scrutiny on those who enable it.

You’ll hear him discuss:

  • The $1.07 million OFAC settlement and the criminal charges against Roman Sinyavsky for sanctions evasion and money laundering
  • How sanctioned Russian oligarchs used non-sanctioned family members and shell companies to obscure their ownership of U.S. properties
  • The key role of real estate professionals, lawyers, and financial advisors in facilitating these schemes and why they should have raised red flags
  • The use of text messages as critical evidence proving intent and knowledge of sanctions violations
  • The specific techniques used to transfer property ownership and avoid detection by authorities
  • The increasing enforcement focus on commercial and residential real estate transactions as a high-risk area for financial crime
  • Predictions for 2024, including tighter sanctions enforcement on Russia and Iran and what it means for businesses and compliance professionals

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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FCPA Compliance Report

FCPA Compliance Report – Workplace Culture and Compliance with Alejandra Almonte and Ann Sultan

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Alejandra Almonte and Ann Sultan, both Members of Miller & Chevalier, and uses the EEOC’s release in 2024 of its Enforcement Guidance on Harassment in the Workplace as an introduction to considering compliance and the workplace under the new Trump Administration.

Ann and Alejandra dive deep into the EEOC’s 2024 enforcement guidance on harassment and explore the implications of recent Executive Orders from the Trump administration. The conversation extends to the necessity of risk assessments in the current climate, focusing on how companies can maintain safe and compliant workplaces amidst shifting policies. Ann and Alejandra share valuable perspectives on conflicts of interest, the intersection of workplace safety and emotional well-being, and strategies for fostering a positive organizational culture even in uncertain times. Do not miss this expert advice on navigating the complexities of workplace conduct and compliance in the evolving legal landscape.

Key highlights:

  • EEOC’s 2024 Enforcement Guidance on Harassment
  • Impact of Policy Changes on Workplace Conduct
  • Ensuring a Safe and Inclusive Workplace
  • Risk Assessments and Workplace Misconduct
  • Conflicts of Interest in the Workplace

Resources:

Miller & Chevalier

Ann Sultan

Ann Sultan on LinkedIn

Alejandra Almonte

Alejandra Almonte on LinkedIn

Culture@Work: Fall 2024

Tom Fox

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Facebook

YouTube

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LinkedIn

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Adventures in Compliance

The Case-Book of Sherlock Holmes: Leadership Lessons from ‘The Adventure of the Retired Colourman’

In this new season of Adventures in Compliance, host Tom Fox delves into Arthur Conan Doyle’s Sherlock Holmes collection, The Case-Book of Sherlock Holmes. It is the final set of twelve Sherlock Holmes short stories, first published in the Strand Magazine between October 1921 and April 1927. This episode considers the story The Adventure of the Retired Colourman.

Tom uses this story to delve into critical business ethics topics, such as due diligence, ethical leadership, delegation, adaptability, and risk management. He highlights how Holmes’ methodical approach to uncovering deception can guide modern executives in navigating the complexities of corporate compliance. Listeners will gain insights into the importance of thorough investigation, transparency, effective delegation, and continuous adaptability in their leadership roles.

Highlights include:

  • Summary of ‘The Adventure of the Retired Colourman’
  • Business Ethics Lessons from Sherlock Holmes
  • Understand risk and its mitigation

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

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

Connect with Tom Fox

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All Things Investigations

All Things Investigations – CFIUS: Balancing Security, Investment and Innovation with Sean Reilly

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by Sean Reilly to explore the Nippon Steel/US Steel transaction.

We begin with an in-depth explanation of the Committee on Foreign Investment in the United States (CFIUS) and its role in scrutinizing foreign transactions for national security risks. The conversation highlights the complex and detailed CFIUS filing process, stressing the importance of early compliance counsel involvement to avoid potential roadblocks. The discussion extensively covers the Nippon Steel and US Steel transactions, pointing out key developments and underlying political influences and analyzing how President Biden eventually barred the potential acquisition.

In an addendum, the conversation also touches on recent changes under the Trump administration, emphasizing the need for companies and compliance officers to adapt dynamically amidst rapidly evolving regulations. Sean advises on practical steps for businesses considering transactions that might trigger CFIUS involvement, underscoring the importance of engaging with the committee early and thoroughly. The episode is an essential guide for corporate compliance professionals navigating the complexities of cross-border transactions and national security considerations.

Key highlights:

  • Understanding CFIUS
  • Nippon Steel and U.S. Steel Acquisition
  • CFIUS Concerns and Political Implications
  • Advice for CFIUS Compliance
  • Developments under Trump and Future Outlook

Resources:

Hughes Hubbard & Reed website

Sean Reilly

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Blog

Building Trust in AI with Blockchain: A Compliance Perspective

Artificial Intelligence (AI) has rapidly become a key driver of business decision-making across industries, from financial services to healthcare. Yet, despite its enormous potential, AI remains a “black box” that raises serious concerns about transparency, accountability, and fairness. According to Pew Research, 52% of Americans are more concerned than excited about AI, while only 10% express enthusiasm. This trust deficit presents a critical challenge for compliance professionals: how can organizations demonstrate responsible AI use and ensure compliance with evolving regulatory expectations?

I was therefore intrigued to read a recent article in the Harvard Business Review by Scott Zoldi and Jordan T. Levine entitled, Using Blockchain to Build Customer Trust in AI. Their response to this quandary was to look at FICO, a leader in financial analysis and ratings, which developed a private blockchain that automated documentation and standards in model development. FICO’s approach leaned directly into a series of strategies used by compliance professionals.

The Compliance Challenge of AI

AI’s ability to analyze vast amounts of data and generate predictions is its greatest strength and its most significant liability. Machine learning models can reinforce biases, lack interpretability, and operate without clear accountability. Compliance professionals must address these challenges head-on by ensuring that AI models are:

  • Interpretable: Customers and regulators need to understand how AI models make decisions.
  • Auditable: Organizations must maintain detailed records of AI development and deployment.
  • Enforceable: Compliance teams need mechanisms to ensure adherence to ethical AI standards.

Without these three pillars, AI risks becoming a compliance nightmare that could lead to regulatory penalties, reputational damage, and loss of customer trust.

Blockchain ensures that AI models are developed following internal guidelines and regulatory requirements. Every modification to the model, from data selection to algorithmic tuning, is permanently recorded, making it easier for compliance officers to track decisions and pinpoint the cause of any discrepancies. This immutable nature benefits industries with strict regulations, such as finance and healthcare, where audits and regulatory reviews are routine.

Additionally, blockchain helps prevent unauthorized alterations by requiring cryptographic verification before changes are accepted into the system. Any attempt to introduce bias, manipulate datasets, or adjust algorithms must be documented and approved transparently. This enhances accountability and strengthens organizational trust in AI.

Blockchain’s integration into AI governance fosters cross-functional collaboration between compliance, legal, and data science teams. Using a single, tamper-proof source of truth, organizations can streamline communication and ensure that AI-related decisions align with corporate policies and industry standards. This collaborative approach mitigates risks and reduces inefficiencies, allowing businesses to innovate responsibly while maintaining regulatory compliance.

For compliance professionals, blockchain provides an operational framework supporting continuous AI model monitoring and improvement. It facilitates real-time oversight, allowing organizations to identify potential compliance risks before they escalate into regulatory violations or reputational damage. As AI technology evolves, blockchain’s role in governance will likely expand, offering even greater opportunities for secure, transparent, and ethical AI development.

Blockchain: A Path to AI Accountability

Blockchain technology offers a potential solution by providing an immutable, transparent record of AI model development and decision-making. The authors reviewed FICO’s adoption of blockchain. They learned, “Making this system work was less a tech challenge than a people one. They learned it was important to start with standards, then develop the tech; that making the system user-friendly was non-negotiable; that it was essential to iterate on quick wins; that they had to build repositories to hold large AI assets in alternate storage; and that they needed capable IT teams to handle the maintenance demands of this system.”

By moving from traditional documentation methods (such as Word documents) to a private blockchain, FICO:

  • Reduced model support issues and recalls by over 90%.
  • Created a single source of truth for AI model development.
  • Ensured absolute adherence to AI governance standards.

Blockchain’s ability to create an auditable trail of every change, test, and decision made during AI model development provides a powerful compliance tool. Unlike conventional documentation, blockchain prevents unauthorized changes and ensures compliance teams can verify AI decisions long after they are made.

Beyond compliance, blockchain enhances the efficiency of AI governance by automating tracking mechanisms that reduce administrative burdens. Traditionally, managing AI development required extensive oversight, documentation, and verification processes, often prone to human error or oversight. By leveraging blockchain, organizations can automate this oversight, ensuring that model updates, training datasets, and algorithmic adjustments are securely recorded in a tamper-proof ledger. This improves compliance and accelerates AI innovation by reducing bottlenecks in model validation.

Additionally, blockchain’s transparency enables better cross-functional collaboration between compliance officers, data scientists, and IT security teams. Instead of relying on disparate documentation and periodic audits, stakeholders can access a real-time, immutable ledger of AI development activities. This fosters greater accountability and ensures that AI models align with ethical guidelines, regulatory requirements, and corporate governance policies from inception to deployment.

Blockchain can mitigate risks associated with AI bias and ethical concerns by providing a structured framework for tracking model modifications and testing processes. Any deviation from approved methodologies is recorded, allowing organizations to detect and address potential issues before they impact decision-making. This proactive approach strengthens AI reliability and fosters trust among regulators, customers, and stakeholders who demand greater transparency in automated decision-making processes.

By integrating blockchain into AI governance, organizations gain a robust compliance tool that ensures models are developed responsibly, deployed ethically, and maintained transparently. As regulatory scrutiny around AI continues to grow, adopting blockchain-based governance is not just an operational advantage; it can provide both a strategy and mechanism for maintaining trust and regulatory compliance in the evolving AI landscape.

Key Compliance Lessons from FICO’s Blockchain Approach

1. Standards Must Come First

Before implementing blockchain, organizations must establish clear AI development standards. This includes defining acceptable algorithms, ethical testing methodologies, and regulatory compliance requirements. Without these guardrails, blockchain is just another technology without purpose.

2. User Adoption Requires a Seamless Experience

One of the biggest hurdles in AI governance is ensuring that data scientists comply with established processes. At FICO, blockchain-based AI governance became non-negotiable—developers could not release models without following the blockchain-tracked workflow. Making compliance seamless rather than burdensome is key to adoption.

3. AI Governance Must Be Iterative

FICO’s blockchain approach evolved, starting with small proofs of concept before scaling across its AI development teams. Compliance professionals should take a similar approach, testing blockchain governance in high-risk areas before expanding its use across the organization.

4. Immutable Records Are Key for Regulatory Defense

Regulators are increasingly scrutinizing AI-driven decisions, especially in highly regulated industries such as finance and healthcare. An immutable AI development, testing, and deployment record provides a powerful defense against regulatory inquiries. It also enables organizations to demonstrate compliance rather than scrambling to justify decisions afterward proactively.

5. Blockchain Is a Tool, Not a Silver Bullet

While blockchain enhances AI governance, it is not a substitute for a strong compliance program. Organizations must still conduct rigorous ethical testing, monitor AI performance, and engage with regulators to ensure ongoing compliance. Blockchain should be viewed as an enabler of trust, not a cure-all.

Final Thoughts: The Future of Compliance in AI Governance

As AI becomes more embedded in business operations, compliance professionals must evolve their oversight strategies to keep pace. Blockchain offers a compelling approach to ensuring AI accountability, but it requires careful implementation, clear governance standards, and buy-in from business leaders.

FICO’s success demonstrates that trust follows when AI governance is built on transparency, auditability, and enforceability. Compliance professionals who embrace blockchain’s potential can help bridge the trust gap in AI, ensuring that these powerful technologies are used responsibly, ethically, and in full compliance with regulatory expectations.

For compliance teams, the question is no longer whether AI governance needs to evolve but how quickly organizations can implement solutions that keep AI accountable. Blockchain is one step in the right direction.

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Daily Compliance News

Daily Compliance News: February 10, 2025, The For Immediate Compliance 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 a cup of morning coffee, and listen in 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:

  • FEMA must call immigrants ‘illegal aliens.’ (404media).
  • CFPB ordered all work to be stopped ‘immediately.’ (NYT)
  • Musk is now making referrals to the US Attorney. (Reuters)
  • McKinsey asks, if China is too risky. (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.