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Data Driven Compliance

Data Driven Compliance – Navigating Self-Disclosure Under the FTPF and Updated ECCT

Welcome to Season 2 of the award-winning Data Driven Compliance. In this new season, we will look at the new Failure to Prevent Fraud offense. Join host Tom Fox as we explore this new law and how to comply with it through the lens of data-driven compliance. This podcast is sponsored by konaAI. In this episode of Season 2, Tom is joined by Simon Airey and Caitlyn Sheard, partners at McDermott Will & Schulte LLP, and both experts in the fields of investigation and compliance from both sides of the Atlantic.

We take a deep dive into their recent article, ‘Cross Atlantic Impact, DOJ and SFO, Self-Reporting and Enforcement Priorities,’ exploring the critical topic of self-disclosure in the context of both U.S. and UK jurisdictions. The discussion covers the incentives for self-reporting under the DOJ’s updated policies, the Serious Fraud Office’s new guidance on voluntary disclosure in the UK, and the broadening scope of anti-economic crime laws, including the UK’s significant changes effective from 2023. The conversation highlights the complexities and strategic challenges companies face in making self-disclosure decisions, the emerging enforcement focus on cartels and economic crimes, and the ongoing robust enforcement of anti-corruption laws such as the FCPA and the UK Bribery Act.

Key highlights:

  • Discussion on Self-Disclosure Incentives
  • Challenges and Implications of Self-Disclosure
  • Changes in UK Law and Its Impact
  • Global Self-Disclosure Strategies

Resources:

McDermott Will & Schulte LLP

Simon Airey

Caitlin Sheard

Cross-Atlantic Impact: DOJ and SFO Self-Reporting and Enforcement Priorities

Click here for konaAI White Paper Rethinking Compliance: Practical Steps for Adapting to the UK’s New Fraud Legislation

Connect with Tom Fox on LinkedIn

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Reel Creators of the Texas Hill Country

Reel Creators of the Texas Hill Country: Exploring the Art of Storytelling with Susan Wilder

Welcome to Reel Creators of the Texas Hill Country, where we dive deep into the heart of filmmaking in one of America’s most unique and captivating landscapes. From rolling hills and rustic towns to thriving cities and hidden gems, the Texas Hill Country offers endless inspiration for filmmakers, and we’re here to uncover every aspect. In this podcast, we’ll meet the passionate directors, cinematographers, screenwriters, and crews who bring their creative visions to life in this storied region. Join us as we explore the challenges, rewards, and unique stories that make filmmaking here an art of its own. Whether you’re a seasoned pro or simply curious about the world behind the camera, Reel Creators of the Texas Hill Country promises to be your all-access pass to the vibrant filmmaking community of the Hill Country and beyond.

In this episode, host Tom Fox welcomes Susan Wilder, a seasoned storyteller, actor, filmmaker, and artist. Susan shares her journey from starting as an actor later in life to transitioning to the other side of the camera as a director and filmmaker. She discusses the importance of storytelling both personally and professionally, the creative process behind directing and filmmaking, and her directorial debut with the film ‘What Remains. Additionally, Susan offers insight into character development, the collaborative nature of filmmaking, and the importance of authenticity. For anyone passionate about storytelling, whether in compliance or the arts, Susan’s message is clear—pursue your passion with dedication and creativity.

Key highlights:

  • The Importance of Storytelling
  • Transitioning from Acting to Filmmaking
  • Directorial Debut and Current Projects
  • Creative Process and Character Development
  • Artistic Pursuits and Inspirations
  • Advice for Aspiring Storytellers

Resources:

Susan Wilder on Instagram

Texas Hill Country Podcast Network

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 61 – The Back to the Future Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

 

Stories this week include:

Connect with the Hosts:

Prove Your Worth

Tom

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Daily Compliance News

Daily Compliance News: October 10, 2025, The Happy Birthday Lou 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, including compliance, ethics, risk management, leadership, or general interest, relevant to the compliance professional.

Top stories include:

  • Corruption in Zimbabwe-I am shocked. (Bloomberg)
  • E-sports and the data privacy maze. (Bloomberg Law)
  • Does Homan have to return the $50K? (NYT)
  • Star witness in Menendez trial to be sentenced. (NYT)
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Popcorn and Compliance

Popcorn and Compliance: Episode 2 – Dracula’s Compliance Secrets: What Lurks in the Night

Welcome to a special series of Popcorn and Compliance. In this series, we will be looking at the Classic Universal Monster Movies from the 30s and 40s and mining them for compliance lessons. (Yes, it really is an excuse to rewatch them all.) In this series, we will look at Frankenstein, Dracula, The Wolf Man, The Mummy, and end with The Invisible Man. In this episode, Tom explores critical compliance insights drawn from Bela Lugosi’s portrayal of Dracula.

Tom dives into five key compliance lessons: the dangers of third-party relationships, the subtle power of influence, the risk hidden in shadows, the importance of cultural awareness, and the perils of complacency. By drawing parallels between Dracula’s methods and modern compliance challenges, the episode underscores the need for rigorous due diligence, continuous monitoring, and a proactive mindset in risk management.

Key highlights:

  • Exploring Count Dracula’s Compliance Lessons
  • Third Parties: Your Greatest Risk
  • The Power of Influence
  • Risk Hides in the Shadows
  • Cultural Blindness Increases Vulnerability
  • Complacency Enables Catastrophe

Resources:

Compliance Lessons from Bela Lugosi’s Dracula on the FCPA Compliance and Ethics Blog

Tom Fox

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AI Today in 5

AI Today in 5: October 10, 2025, The Romantic AI Edition

Welcome to AI Today in 5, the newest edition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI, so start your day, sit back, enjoy a cup of morning coffee, and listen in to the AI Today In 5, all from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest related to AI.

Top AI stories include:

  1. How does AI think? (WSJ)
  2. Can you trust your eyes anymore? (NYT)
  3. 20% of high schoolers have romantic relationships with AI. (NPR)
  4. Saunders says AI will cost 100MM jobs. (Yahoo!News)
  5. Data quality and AI. (Global Newswire)
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Compliance Tip of the Day

Compliance Tip of the Day – Compliance Lessons from Wells Fargo’s AI-Assisted Whistleblower Program

Welcome to “Compliance Tip of the Day,” the podcast that brings 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, our goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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 conclude our look at how companies are using AI in their business operations and draw compliance lessons from this use for compliance professionals. Today, we continue with compliance lessons from Wells Fargo’s development of an AI-assisted tool to help in the triage of whistleblower complaints.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Fox on Podcasting

Fox on Podcasting – The Evolution of Podcasting: Insights from Rob Greenlee

Join Tom Fox as he explores the world of podcasting and get ready to be inspired to start your own podcast. In this episode, Tom welcomes Podcasting Hall of Fame Chairperson Rob Greenlee.

Rob is a prominent figure in the podcasting industry. He and Tom discuss the evolution of podcasting, including the shift from audio to video content, the business consolidation within the industry, and the increasing importance of monetization. Rob shares insights on the potential of local podcasts for businesses and the potential impact of AI on the medium. They end with a reflection on the late Todd Cochrane’s contributions to podcasting. Rob also talks about his current projects, including his work with multiple podcast networks.

Key highlights:

  • Current Projects
  • The Evolution of Podcasting
  • Podcasting Hall of Fame
  • Future of Podcasting
  • Tribute to Todd Cochrane

 Resources 

Rob Greenlee on LinkedIn

Website

Artwork

Elaine Capers

Art by Elaine

Tom

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Blog

Compliance Lessons from Bela Lugosi’s Dracula

As many of my readers know, I am a huge fan of the Classic Universal Picture Movie Monsters, focusing on the period from 1931 to the mid-1950s. In October, I traditionally use our Halloween-ending month to explore the Classic Universal Movie Monsters, along with other films from the Hammer Studio, those produced by Val Lewton, and those starring Vincent Price.  This year, I wanted to go back to basics by looking at the Classic Universal Movie Monsters, starting with Dracula and Frankenstein in 1931, followed by The Invisible Man in 1933, The Mummy in 1936, and ending with The Wolf Man in 1940.

Over the next five weeks, I will examine each of these movies through the lens of compliance and extract compliance lessons from each one. Today, I continue with the Classic Universal Movie Monster, Bela Lugosi’s version of Dracula. If you want to take a deeper dive into this movie in the podcast format, check out the special series on Popcorn and Compliance, hosted by my friends Fiona and Timothy. These podcasts will be posted alongside the blog post each Friday during October.

When Bela Lugosi first spoke the words, “I am Dracula,” in Tod Browning’s 1931 classic, audiences were mesmerized. His piercing stare, deliberate speech, and aristocratic charm redefined horror cinema. But beneath the gothic atmosphere lies something compliance professionals know all too well: the dangers of deception, unchecked power, and the failure to recognize risk until it’s too late.

The Lugosi Dracula is not just a horror film; instead, think of it as a parable of compliance. The Count operates as a smooth-talking third-party who gains access, conceals his true motives, and ultimately causes destruction when left unmonitored. For the corporate compliance professional, there are striking lessons in risk management, due diligence, and the importance of cultural awareness.

We continue our look at the Classic Universal Monster Movies by reviewing five key compliance lessons from the Lugosi Dracula.

1. Third Parties Are Your Greatest Risk

Dracula does not walk into London as a monster. He enters as an exotic nobleman, charming, well-spoken, and seemingly trustworthy. The people around him take him at face value. Only too late do they discover the truth: he is feeding off their lifeblood. This is the archetype of third-party risk. Business partners, agents, or distributors may present themselves as polished and reputable, but without thorough due diligence, they can bring immense legal and reputational risk.

Compliance takeaway: Treat every third-party relationship as a potential source of risk. Conduct due diligence, monitor relationships, and never rely solely on surface-level reputation. A charming exterior may conceal dangerous intentions.

2. Beware the Power of Influence

One of Lugosi’s most memorable traits is his hypnotic gaze. With it, he bends others to his will: Renfield, Mina, and Lucy, as each falls victim not by force, but by subtle manipulation. In the compliance world, influence is often exerted by powerful executives, dominant cultures, or high-performing employees. When individuals exercise undue influence, they can pressure others to bend the rules, ignore red flags, or accept unethical behavior as usual.

Compliance takeaway: Compliance officers must watch for undue influence in corporate cultures. Strong tone from the top matters, but so does tone in the middle. Employees must feel empowered to resist pressure, report concerns, and recognize when influence becomes coercion.

3. Risk Hides in the Shadows

Much of the horror in Dracula comes not from what is seen, but from what lurks in the shadows. The Count moves by night, unseen, exploiting darkness to conceal his actions. By the time victims realize what has happened, the damage is already done. This resonates with how misconduct often operates in organizations. Corruption, fraud, and abuse typically occur out of sight, through falsified invoices, shell companies, or hidden payments. By the time regulators or auditors arrive, the harm is already inflicted.

Compliance takeaway: Continuous monitoring and data analytics are the compliance professional’s tools for shining light into the shadows. Proactive detection: real-time alerts, AI-driven monitoring, and transactional reviews help catch misconduct before it metastasizes.

4. Cultural Blindness Increases Vulnerability

One of the early warnings comes from the locals in Transylvania, who beg Jonathan Harker not to go to Dracula’s castle. They know the legends, they understand the risks, and they offer charms for protection. Yet he dismisses them as superstition. This is a classic case of ignoring cultural risk signals. In multinational operations, compliance failures often occur when the headquarters dismisses local knowledge, customs, or warnings. By failing to respect the insights of those closest to the risk, organizations make themselves vulnerable.

Compliance takeaway: Listen to local voices. Local compliance officers, employees, and partners often see risks first. A compliance program that ignores or downplays its input is doomed to fail. Respecting cultural context is essential for effective risk management.

5. Complacency Enables Catastrophe

Finally, one of the key reasons Dracula thrives in London is that no one believes such evil could exist among them. Van Helsing recognizes the threat, but others mock him or rationalize the strange events. Denial and complacency give Dracula the space to flourish. In corporate compliance, complacency is equally dangerous. When companies assume “it can’t happen here,” they let their guard down. When managers dismiss warning signs as anomalies, they enable misconduct to spread. Complacency is the enemy of effective compliance.

Compliance takeaway: Compliance professionals must cultivate vigilance. Risk assessments should be ongoing, investigations must be taken seriously, and whistleblower reports must never be ignored. The moment an organization believes it is immune, it becomes most vulnerable.

Conclusion: Dracula in the Boardroom

Bela Lugosi’s Dracula is remembered for its elegance and terror. But for compliance officers, it offers something more: a reminder that risk often comes disguised as opportunity, that influence can corrupt, that danger thrives in shadows, that cultural insights matter, and that complacency kills.

Just as Van Helsing armed himself with crucifixes, garlic, and sunlight, compliance professionals must arm their organizations with due diligence, monitoring, cultural awareness, and vigilance. The Lugosi Dracula teaches us that evil is not always obvious; rather, it often comes in a tuxedo, with a charming smile and a foreign accent, promising value while draining the lifeblood of those who trust too easily.

The compliance professional’s mission is clear: don’t let Dracula through the door without asking the hard questions, shining the light into dark places, and ensuring that your organization is prepared for what lurks in the night.

Join us next Friday as we jump to 1940 and consider compliance lessons from Lon Chaney Jr.’s The Wolf Man.