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Life with GDPR

Life With GDPR: Cookie Compliance

Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. In this episode, they discuss Cookie Compliance Under GDPR.

Their discussion highlights the increasing enforcement actions surrounding website cookies, emphasizing that this is a data protection issue and a broader compliance challenge. Specific case studies, such as the Dutch regulator’s fine against Pool Blue and fines in other EU countries, illustrate the significant financial penalties companies can face for non-compliance. Jonathan outlines an eight-point plan to help organizations ensure their cookie practices are current, including regular checks, proper configuration of cookie banners, and transparency about data retention periods.

The episode also touches on the role of third-party cookies, potential litigation, and regulatory actions. Compliance with cookie regulations is becoming increasingly important, with groups like NOYB driving many complaints and regulatory bodies across Europe ramping up enforcement efforts. Listeners are encouraged to assess their cookie practices and make necessary adjustments to avoid fines and maintain compliance.

Key takeaways:

  • The Rise of Cookie Enforcement
  • Global Fines and Consequences
  • Practical Compliance Tips
  • Challenges with Cookie Banners
  • Understanding Your Own Cookies
  • Guidelines for Cookie Retention

Resources:

Connect with Tom Fox

Connect with Jonathan Armstrong

Life with GDPR was recently honored as a Top Data Security Podcast.

Categories
Blog

Compliance Leadership Week: Compliance Teams – Cracking the Code for Enhanced Effectiveness

We continue looking at leadership in the compliance function based on a series of recent articles by McKinsey on personal and team leadership. Today, we migrate from individual leadership lessons and issues to issues of compliance team leadership. This is for leadership internal to the corporate compliance function and leadership by the corporate compliance function within the greater organization. We use the article Go, teams: When teams get healthier, the whole organization benefits by authors Aaron De SmetGemma D’Auria,  Maitham Albaharna, and Anaïs Fifer, all with McKinsey, as a starting point for our exploration.

The stakes for effective teamwork have never been higher in the corporate compliance landscape. Teams have become the fundamental drivers of performance and value creation. This rings especially true within compliance departments, where cross-functional and inter-departmental collaboration is desirable and essential for regulatory adherence and ethical excellence. Yet, despite the rise in team autonomy and empowerment, many teams struggle significantly with collaboration and achieving measurable outcomes.

Research supports the harsh reality that three out of every four cross-functional teams fall short of expectations, performing below key metrics. This concerning statistic signals that organizations—and compliance departments in particular—must urgently reassess their approach to building, nurturing, and sustaining high-performing teams.

Debunking the Myths of Team Effectiveness

Two prevalent misconceptions frequently undermine organizational efforts to enhance team performance. First is the myth of the “heroic team leader,” the notion that a talented individual at the helm ensures collective success. Secondly, believing in “team chemistry,” or that teams naturally either click or don’t, fails to provide actionable insights. Both narratives obscure the critical structural and contextual factors shaping team outcomes.

Indeed, leadership skills are crucial. Equipping team leaders with enhanced competencies can yield incremental improvements. Yet, as compliance professionals, we must acknowledge that great leaders alone aren’t enough. Effective compliance teamwork goes beyond individual capabilities and chemistry—it is less art and more a science, demanding strategic consideration of deeper structural elements and systemic behaviors that drive genuine effectiveness.

Team Effectiveness: Moving Beyond Intuition

Compliance leaders often rely on intuition or experience to assemble teams, assuming that stacking teams with top talent automatically ensures optimal outcomes. Yet, this intuitive approach frequently misses the mark. Team effectiveness hinges less on the aggregation of individual “stars” and more on carefully balancing roles, skills, and collective behaviors aligned to the team’s specific purpose.

The U.S. men’s Olympic 4×100-meter relay team is a vivid example of this principle. Despite boasting individual runners of extraordinary speed and skill, repeated baton-passing issues have undermined their overall performance, notably resulting in disqualification at the 2024 Olympics. This illustrates a crucial compliance lesson. Top individual performers cannot guarantee collective success without effective coordination and practiced team collaboration.

Translating this to compliance, consider a team conducting an internal investigation. Staffing this team solely with the organization’s most talented individual specialists may seem sensible. However, without clearly defined roles, purposeful team interaction, and practice collaboration, such a team risks missteps, redundancies, or critical oversight, potentially exacerbating compliance risks.

The Science of Effective Compliance Teams

Recent research has pinpointed specific behaviors that drive team effectiveness, a concept we term “team health drivers.” These drivers represent actionable behaviors that consistently correlate with high-performing teams, which are particularly valuable for compliance professionals navigating intricate regulatory environments.

These health drivers fall under four essential pillars:

  1. Defining clear roles and ensuring diversity of perspectives and skills on the compliance team.
  2. Guaranteeing team clarity and unified commitment to the compliance program’s objectives and regulatory obligations.
  3. Assessing and enhancing how effectively the compliance team executes responsibilities, from risk assessment to enforcement.
  4. Establishing a sustainable work environment that allows compliance teams to maintain effectiveness long-term.

Applying these pillars practically, compliance officers can proactively diagnose and strengthen team effectiveness, resulting in robust regulatory adherence and enhanced organizational integrity.

Context Matters: Compliance Team Archetypes

Not every team requires identical behaviors to achieve effectiveness. Recognizing distinct team archetypes and contexts allows compliance leaders to tailor approaches more precisely. For example, investigative compliance teams may require stringent execution and clearly defined configuration. In contrast, compliance advisory teams interacting closely with business units might prioritize alignment and renewal behaviors to sustain effective long-term partnerships.

Understanding context-specific behaviors empowers compliance leaders to design teams strategically. Rather than generic team-building exercises, focus resources on targeted development areas precisely aligned to specific compliance team functions and organizational goals.

Creating Value Beyond the Top Team

Traditionally, organizations predominantly direct resources toward enhancing senior leadership teams, perceiving them as the greatest value drivers. While top-level alignment is undoubtedly vital, compliance leaders must recognize the indispensable role of middle management and operational compliance teams.

Teams closest to the organization’s front lines, such as customer-facing compliance staff, offer critical real-time insights into emerging risks and operational challenges. Prioritizing these teams can unlock significant value, enhance organizational responsiveness, and empower proactive compliance.

The Imperative for Compliance Leaders

Compliance leaders must embrace evidence-based team effectiveness approaches to navigate today’s fast-evolving regulatory landscape. Debunking myths, adopting scientifically validated team health drivers, and recognizing context-specific nuances position compliance departments for greater strategic impact.

As compliance professionals, the commitment to effective teamwork isn’t merely an administrative detail; it is fundamental to achieving sustained organizational integrity and robust regulatory compliance. The time is now to crack the code on compliance team effectiveness, transforming our teams from collections of talented individuals into cohesive units delivering exceptional collective outcomes.

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The Hill Country Podcast

The Hill Country Podcast – A Conversation with Dr. Charlie McCormick

Welcome to the award-winning The Hill Country Podcast. The Texas Hill Country is one of the most beautiful places on earth. In this podcast, Hill Country resident Tom Fox visits with the people and organizations that make this the most unique area of Texas. This week, Tom welcomes Dr. Charlie McCormick to discuss the innovative changes and plans at Schreiner University.

Tom welcomes back Dr. Charlie McCormick, the President of Schreiner University, to discuss the significant developments from the 2024-2025 academic year and look ahead to the 2025-2026 academic year. Dr. McCormick highlights the new initiatives at the university, including the Center for Talent and Workforce Development, the launch of a mechatronics program, and the new football team. He also emphasizes the university’s commitment to serving rural students and families, discussing the establishment of a rural banking program and the effort to ensure affordability and value in education. Additionally, Dr. McCormick gives a sneak peek into next year’s exciting developments, including the official launch of football, a new women’s flag football team, and innovative educational programs at the Texas Center.

Key highlights:

  • Highlights of the 24-25 Academic Year
  • Center for Talent and Workforce Development
  • Exciting New Programs: Mechatronics and Football
  • Expanding Academic Programs and Focus on Rural Banking
  • Commitment to Rural Students

Resources:

Schreiner University

Nancy Huffman Fine Art

Other Hill Country Focused Podcasts

Hill Country Authors Podcast

Hill Country Artists Podcast

Texas Hill Country Podcast Network

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Compliance Into the Weeds

Compliance into the Weeds: Global Anti-Corruption Leadership

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly are joined by Mary Inman, a founding partner at Whistleblower Partners.

Matt, Tom, and Mary reflect on the global response to anti-corruption measures following an executive order issued by former President Trump. The conversation highlights webinars conducted in early 2025 that addressed concerns over who would enforce anti-corruption laws worldwide if the United States stepped back. The sentiment among countries like Brazil, Hong Kong, Singapore, England, and France was clear; they were ready to take on the mantle themselves.

Mary reports on her conversations with the SFO in London about instituting a whistleblower program and similar initiatives in the United Kingdom at His Majesty’s Revenue and Customs and the Financial Conduct Authority.

Key highlights:

  • Global Anti-Corruption Sentiment Post-Trump’s Executive Order
  • Encouraging International Enforcement
  • Evidence of Global Enforcement Actions
  • Whistleblower Incentives in the UK
  • Global Leadership in Anti-Corruption

Resources:

Mary Inman on LinkedIn

Whistleblower Partners

Matt in Radical Compliance 

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Categories
Great Women in Compliance

Great Women in Compliance: The Future of Enforcement with Jennifer Lee

In this Great Women in Compliance episode, Hemma hosts Jennifer Lee, a partner at Jenner & Block and former Assistant Regional Director at the SEC. The discussion covers Jennifer’s work in SEC investigations, the importance of integrity in legal practice, and key challenges faced by compliance professionals, including evolving cybersecurity obligations and the future of FCPA enforcement.

Tune in today to hear Jennifer share her insights on maintaining ethical standards, managing client expectations during investigations, and the value of community and mentorship in the legal profession.

Highlights include:

  • How to avoid the slippery slope to enforcement
  • Insights on values-based decision-making from Jennifer’s reading list
  • What our clients need most from legal and compliance counsel
  • Perspectives from a former federal prosecutor at the SEC
  • What compliance officers should be thinking about today

Biography:

A former Assistant Director in the US Securities and Exchange Commission’s (SEC) Division of Enforcement, Jen represents public and pre-IPO companies, corporate officers, financial institutions, and asset management firms in high-stakes regulatory, internal, and litigation investigations.

During her distinguished 12-year tenure at the SEC, Jen worked on and supervised attorneys and accountants involved in a broad range of complex investigations and enforcement actions reflecting the priorities of the SEC’s enforcement program, including financial reporting and disclosures, cybersecurity issues, ESG-related issues, insider trading, investment adviser and broker-dealer regulation, auditor misconduct, and offering frauds. Jen oversaw some of the SEC’s most impactful cases, including the SEC’s first-of-its-kind cybersecurity disclosure enforcement action involving a company’s failure to disclose a massive data breach, several litigated multimillion-dollar insider trading ring actions, and a complex accounting fraud settlement involving significant clawbacks of executive compensation under Section 304 of the Sarbanes-Oxley Act of 2002.

Highly regarded for her knowledge of the SEC’s enforcement program and federal securities laws, Jen’s articles regularly appear in the Harvard Law School Forum on Corporate Governance, and she has been quoted numerous times in the Washington Post, CNBC, and Law360, particularly on the topics of financial reporting and cybersecurity. Jen has appeared as a speaker at the cybersecurity conference BlackHat and as a panelist at Securities Enforcement Forum West, Securities Forum Central, and the Bar Association of San Francisco. Jen is a member of the steering committee of Women in Securities (WISe), the steering committee for the Cambridge Forum regarding SEC enforcement, and the advisory committee for Securities Docket.

Jen earned her AB from Stanford University and her JD from Columbia Law School. She clerked for the Honorable Richard J. Holwell in the US District Court for the Southern District of New York and the Honorable Roger L. Gregory in the US Court of Appeals for the Fourth Circuit. Before joining the SEC, Jen was a securities and commercial litigator with experience in securities fraud class actions, commercial actions, and product liability litigation.

🎧 Listen now on your favorite platforms, the Compliance Podcast Network and Corporate Compliance Insights

♥️ Thanks as always to our wonderful #GWIC community for your support. Have an idea or suggestion? Drop a note to Lisa Fine or Hemma Lomax.

Categories
Daily Compliance News

Daily Compliance News: March 26, 2025, The Missile Strike on Boeing 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 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:

  • Judge orders Boeing to trial. (WSJ)
  • Mintz staff freed after 2 years in Chinese jail.  (BBC)
  • Blatter and Platini were cleared of corruption charges.  (Reuters)
  • Washington – we have an off-channel messaging problem. (NYT)
Categories
TechLaw10

TechLaw10: Agentic AI – What Is It & What Are The Risks?

In this film, Punter Southall Law’s Jonathan Armstrong discusses Agentic AI with Professor Eric Sinrod from his home in California. This is episode 291 in the popular TechLaw10 series.

The podcast includes top tips to help avoid issues when using Agentic AI. Jonathan & Eric discuss various aspects of the law’s impact on Agentic AI, including:

  • data location issues after regulatory activity against Deepseek
  • transparency
  • due diligence
  • decision-making in light of a recent ECJ decision
  • the impact of the EU AI Act
  • patent risk & other disclosure risks
  • bias & discrimination
  • existing laws like sanctions, procurement & IP

Jonathan also looks at a 3-step plan to reduce risk

  • understand the tech
  • look at rule setting for agents
  • consider a human in the loop, at least initially

Jonathan talked about the EU AI Act. There are FAQs on that here: The EU Artificial Intelligence Act. There is also a glossary of AI terms here: EU AI Act Glossary: Key terms & acronyms.

Jonathan discusses a recent ECJ judgment involving automated decision-making, and Eric discusses a case involving a hearing-impaired job applicant.

You can learn more about Eric at Duane Morris LLP: https://www.duanemorris.com/attorneys/ericjsinrod.html and Jonathan here at Punter Southall Law: https://puntersouthall.law/about-us/jonathan-armstrong/

Connect with the Compliance Podcast Network at:

LinkedIn: https://www.linkedin.com/company/compliance-podcast-network/

Facebook: https://www.facebook.com/compliancepodcastnetwork/

YouTube: https://www.youtube.com/@CompliancePodcastNetwork

Twitter: https://twitter.com/tfoxlaw

Instagram: https://www.instagram.com/voiceofcompliance/

Website: https://compliancepodcastnetwork.net/

Categories
Blog

Compliance Leadership Week: Leading from the Inside Out

In the compliance profession, we are well-versed in managing intricate policies, navigating regulatory expectations, and ensuring that our organizations achieve the highest standards of corporate integrity. However, I have observed throughout my years as a Compliance Evangelist that compliance professionals, much like CEOs, often overlook the importance of leading from the inside out. Today, we discuss why a human-centric approach to leadership has become necessary, not just an aspiration for compliance executives.

I recently found some interesting observations in an article entitled The ‘Inside Out’ leadership journey: How personal growth creates the path to success by authors Dana MaorHans-Werner KaasKurt Strovink, and Ramesh Srinivasan. This article comes from a chapter in their book, The Journey of Leadership.

In this article, the authors identified a significant gap between their carefully cultivated business skills and their ability to translate these into effective organizational performance. These leaders had mastered financial acumen, strategic management, and operational excellence, yet they struggled to authentically connect their aspirations to the broader goals of their teams and organizations.

Compliance leaders can also fall into this trap. We immerse ourselves in laws, regulations, and compliance frameworks yet sometimes neglect the equally critical personal dimensions—self-awareness, humility, empathy, resilience, and authenticity—that underpin effective compliance leadership. In this blog post, we will consider this fascinating business phenomenon closely and explore its implications for the compliance profession.

Why Human-Centric Leadership Matters in Compliance

Today’s compliance leaders can no longer rely solely on technical mastery in a fast-moving, complex global environment characterized by rapid digital transformation, unprecedented regulatory demands, and mounting stakeholder expectations. Just as the “imperial CEO” era has passed, so too must the image of compliance professionals as merely legal technicians or gatekeepers fade away. Our profession demands a deeper, more reflective, and more human approach to leadership.

Leadership today requires more than simply managing regulatory requirements and organizational risks. It requires an authentic connection with our teams, stakeholders, and ourselves. Compliance leaders must adopt a human-centric approach, guiding people through difficult ethical decisions, fostering a culture of integrity, and inspiring the organization toward a broader societal purpose.

The Inside-Out Approach

The inside-out leadership model involves an intense focus on self-reflection and self-awareness. It calls upon us to examine the mechanics of compliance and our personal motivations, biases, fears, and aspirations. Compliance professionals must reflect on who we are, how we communicate, and how we influence our organizations.

What personal biases or assumptions do we bring into our compliance programs? Where do our blind spots reside? How can we be more empathetic when investigating difficult ethical breaches or compliance failures? The ability to answer these questions candidly and with vulnerability is not just desirable; it is essential.

Consider the parallels: when leaders carefully examine their inner selves, they become better positioned to manage their organizations’ competing demands and priorities. In compliance, this introspection can be transformative. A compliance officer who models self-awareness and humility can dramatically enhance trust within their organization. Trust, after all, is the lifeblood of compliance effectiveness.

Human Leadership in the Age of AI

Technology is reshaping every facet of our lives, and compliance is no exception. Artificial intelligence (AI), machine learning, and generative AI are already streamlining routine compliance tasks, from monitoring transactions to flagging potential ethical issues. While these advancements offer tremendous efficiency, they simultaneously amplify the need for compliance leaders to focus on the distinctly human dimensions of leadership.

Employees increasingly turn to automated tools and platforms for technical compliance guidance. They seek compliance leaders not simply as sources of information but as empathetic coaches, trusted advisors, and ethical role models. Compliance professionals who effectively marry technological tools with human-centric leadership will not only increase their relevance but also profoundly enhance the compliance function’s organizational influence.

This expectation shift was underscored by a recent survey indicating that employees often trust AI-based guidance over human management in purely analytical scenarios. However, humans remain unmatched in critical areas like ethical decision-making, cultural integrity, and organizational purpose. Compliance leaders, therefore, need to leverage AI not as a replacement but as a complementary tool, thereby enabling greater focus on personal connection, ethical mentoring, and culture-building activities.

Stories from the Field

We see powerful examples of leaders successfully adopting this human-centric approach. Consider the CEO of a global automotive corporation who transformed his leadership style by deeply engaging with his executives’ journeys before offering coaching. Or the healthcare leader who mobilized teams through genuine emotional connections, cultivating trust at all levels.

These examples offer clear lessons for compliance leaders. Imagine the impact when a Chief Compliance Officer builds authentic relationships throughout the organization, becoming a trusted counselor rather than an enforcer. Compliance professionals who take this inside-out approach consistently report better outcomes, more robust engagement, and enhanced organizational compliance culture.

The Bottom Line

Data clearly show that companies emphasizing human-centric leadership outperform those solely focused on financial metrics. Organizations that integrate human skills and technological capabilities exhibit greater resilience, sustained profitability, and less volatility. Compliance leaders who embrace an inside-out leadership journey can drive similar outcomes within their functions.

Compliance professionals are no longer confined to enforcing rules or monitoring regulations. Our mandate is more expansive: to authentically connect, inspire ethical behavior, and cultivate trust-based relationships at every organizational level. By embracing a human-centric leadership model, compliance officers can lead more effectively, resonate more deeply, and impact more profoundly.

Compliance has always been fundamentally about people. As compliance professionals, when we invest in our human leadership journey, we unleash our fullest potential to influence, inspire, and transform our organizations from the inside out.

Categories
Compliance Tip of the Day

Compliance Tip of the Day – Leading from the Inside Out

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 discuss why a human-centric approach to leadership has become necessary, not just an aspiration for compliance executives.

Categories
Word of the Week

Word of the Week with Kenneth O’Neal – The Power of One: Embracing Individual Impact

Each week, Kenneth O’Neal discusses a word that describes a principle or value of the Qualities of Success. We suggest you use the Word of The Week in your thoughts, deeds, and actions. You might possess the quality and desire to develop it to a higher level.  You could replace a bad habit with a good habit. Write an action step and use it daily to develop the Quality in your life.

In this episode, Kenneth discusses the word – One and underscores a single individual’s profound influence within their community and industry, focusing on the ‘Power of One.’ He shares an inspiring story of a once-shy student who transformed into a confident public speaker and leader, illustrating each person’s potential to make a difference. Kenneth challenges listeners to embrace their unique abilities and step into roles where their contributions are pivotal. The discussion draws on historical and personal examples, reinforcing that one voice, action, or idea can spark significant change. Listeners are encouraged to identify how to be the ‘one’ in their respective fields, particularly in corporate compliance, where individual accountability and leadership are vital.

Key highlights:

  • The Power of One: Inspiring Story
  • Historical Examples of the Power of One
  • Call to Action: Be the One

Resources:

KRONEAL Consulting