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Compliance Leadership in the 2025 and Beyond

All leadership in the 21st century is undergoing a significant transformation. Traditional leadership styles and models are no longer adequate for the complex and rapidly changing world we find ourselves in. In a recent episode of the leadership podcast that Tom Fox hosts, Dan Silberberg, a leadership expert and founder of the Leader Council Program, emphasized this message. This is significant to all chief compliance officers, compliance leaders, and compliance professionals aspiring to the CCO chair.

Silberberg has developed a year-long program designed to enhance the engagement and effectiveness of C-suite executives. The program helps leaders understand their thought patterns and behaviors, providing benefits like promotions and increased visibility within their organizations. It also addresses the need for adaptable leadership styles to cater to different generations in the workplace, emphasizing the importance of understanding what motivates each generation.

One of the significant shifts in leadership is the move from traditional hierarchical business models to ecosystem-based models. This model is essential for the compliance professional as it prioritizes integrity, competence, and value alignment. Instead of top-down command and control structures, self-managed groups are becoming more prevalent. Within these groups, individuals are empowered to make decisions based on integrity, competence, and shared purpose. This approach allows for greater engagement and input from all members, regardless of their generation.

The key for the compliance professional is two-fold. The first is to recognize such groups within your organization and to reach them with communications and ongoing messaging on compliance so that they might cascade this into the group. The second is to recognize this within your compliance function and how, as a CCO, you manage your compliance team going forward.

Another critical area for the CCO and compliance professional is the literal generations of employees across the workspace. Your work environment could include employees from the Greatest Generation, Boomers, GenXers, Millennials, and GenZers. The presence of five generations in the workplace poses a unique challenge for compliance functions and compliance leaders. Each generation has different focuses, buzzwords, ways of communicating, and ways of thinking. The traditional, one-size-fits-all approach to leadership is no longer practical. Instead, leaders need to embrace the diversity of generations and create an environment where everyone’s input is valued. By aligning values, principles, and purpose, leaders can engage all generations and build a sense of meaning and purpose in their work.

Another challenge in leadership development is the transition from technical expertise to middle management roles. Highly technically competent individuals are often promoted to middle management without the necessary leadership skills. This can lead to difficulty in responding to employee concerns and effectively managing teams. To succeed, you must address this gap by providing middle managers with the necessary leadership skills, such as empathy and emotional intelligence. This is of paramount importance around your speak-up culture and internal reporting. Middle managers are most often the first choice for employees to raise concerns, and empathy and emotional intelligence are critical skills for obtaining information from employees who want to speak up and then reporting it up the chain to compliance for evaluation and action.

As a CCO or compliance leader, you will find that leadership development is centered around self-awareness and conscious decision-making. By understanding one’s own thought patterns, behaviors, and emotional reactions, compliance leaders can gain insights into their strengths and areas for improvement. A leadership program where you are exposed to different situations and guided to track back their reactions to their underlying causes process allows for personal growth and new behaviors and outcomes.

Compliance leaders can create positive organizational change and inspire others to do the same by focusing on individual growth and self-improvement. This is important for both your leadership across the organization in compliance and for your compliance team.

Compliance leadership in the 21st century requires shifting from traditional models to more adaptable and inclusive approaches. Understanding the motivations and values of different generations is crucial for engaging all workforce members. Developing middle managers with leadership skills is also essential for effective team management. Leaders can unlock their potential and create positive organizational change by fostering self-awareness and conscious decision-making. As compliance leaders, whether as CCOs or compliance professionals, a comprehensive and transformative approach to leadership development in 2025 and beyond will be a critical skill to garner.

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Compliance Tip of the Day

Compliance Tip of the Day: Consistency in Compliance

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, our aim is to provide you with 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.

In this episode, we consider why consistency is a mandatory aspect of your compliance regime.

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Everything Compliance - Shout Outs and Rants

Shout Outs and Rants – Episode 129, The Navalny Tribute Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. On this Shout Outs and Rants episode, Tom Fox hosts the quintet of Jonathan Marks, Jonathan Armstrong, Matt Kelly, Karen Woody, and Jay Rosen.

  1. Jonathan Armstrong rants about Julian Assange’s inane claims to be a journalist.
  2. Matt Kelly shouts out to Alexei Navalny, who was murdered for his fight against corruption in Russia.
  3. Karen Woody rants about the senseless gun culture in America.
  4. Jay Rosen shouts out the movie Love on the Spectrum and the Bill Bradley interview.
  5. Tom Fox shouts out to Ben Affleck for his ‘The DunKings’ Super Bowl commercial.
  6. Jonathan Marks has an epic rant on insider trading and the invidious American gun culture.

The members of the Everything Compliance are:

The host, producer, and ranter (and sometimes 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 Compliance Podcast Network.

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Daily Compliance News

Daily Compliance News: February 20, 2024 – The Consent Order Terminated 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.

In today’s edition of Daily Compliance News:

  • The Wells Fargo Consent Order was terminated. (WaPo)
  • Deliberations begin in the NRA corruption trial. (The Guardian)
  • Can racists use free speech arguments to avoid anti-racism training? (Reuters)
  • Should you get your bags in less than 30 minutes? (BBC)

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Innovation in Compliance

Innovation in Compliance: Jay Rosen on Navigating Ethics and Compliance Challenges Through Self – Monitoring

Innovation comes in many forms, and compliance professionals need to not only be ready for it but also embrace it. Today, I visited with well-known compliance professional Jay Rosen to discuss how companies can improve their compliance programs through self-monitoring.

Jay Rosen is a seasoned professional with a background in investment banking and a keen interest in ethics and compliance programs. Rosen’s perspective on ethics and compliance programs is shaped by his extensive analysis of FCPA enforcement actions over the past decade. He believes that companies should carefully consider their internal setup before deciding whether to bring in a third party for assistance. He suggests that while an outside perspective can sometimes lead to a deeper investigation, a mature ethics and compliance program with sufficient resources in-house can also be effective. Rosen emphasizes the importance of objectivity in these programs and proposes a compromise of working with a fractional monitor if the company lacks the necessary headcount. He sees the increasing use of data analytics and self-reporting as key factors in improving ethics and compliance efforts within organizations.

Resources:

Jay Rosen on LinkedIn | Twitter

Tom Fox

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Data Driven Compliance

Data Driven Compliance: From Cutting Edge to Best Practices to Table Stakes

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than Tom Fox’s award-winning podcast, Data-Driven Compliance. This podcast features an in-depth conversation about the uses of data and data analytics in compliance programs. Data-Driven Compliance is back with another exciting episode. Today, I take a solo turn to explore how data-driven compliance has moved from cutting-edge compliance to part of a best practices compliance program to becoming table stakes to do business in a multi-national world.

Data-Driven Compliance Programs are revolutionizing companies’ identification of potential compliance issues, mitigating risks, and maintaining integrity. The Department of Justice has given these programs, which use data analytics and AI, the go-ahead because of their capacity to improve business efficiency and stop improper payments. The bottom line is that these programs have transitioned from being cutting-edge to being considered best practices.

Active data monitoring and analysis, inter-departmental collaboration, and formal risk assessments are cornerstones of a robust compliance program. This is because of the power of data analytics and AI in compliance monitoring and the need for compliance professionals to adapt continuously to the evolving landscape of data-driven compliance. Implementing a data-driven compliance program avoids trouble and enhances business efficiency in today’s regulatory environment.

Tom Fox 

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Compliance Week Conference Podcast

Compliance Week 2024 Speaker Preview Podcasts – Mary Shirley on Living Your Best Compliance Life

In this episode of the Compliance Week 2024 Preview Podcasts series, Mary Shirley discusses her workshop at Compliance Week 2024, “Living Your Best Compliance Life,” based on her book of the same title. Some of the issues she will discuss in this podcast and her presentation are:

  • A session for rising stars;
  • How to position yourself to lead in compliance; and
  • Hearing more from government officials and more about FEPA.

I hope you can join me at Compliance Week 2024. This year’s event will be held April 2-4 at The Westin Washington, DC, Downtown. The line-up for this year’s event is first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event, offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 19th year, join 500+ compliance, ethics, legal, and audit professionals who gather to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. Compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs, among many others, to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 80+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from panels on leadership, fraud detection, confronting regulatory change, abiding by cross-border rules and regulations, and the always favorite fireside chats.
  • Bring actionable takeaways to your program from various session types, including cyber, AI, Compliance, Board obligations, data-driven compliance, and many others, for you to listen, learn, and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. As an extra benefit to listeners of this podcast, Compliance Week is offering a $200 discount on the registration price. Enter the discount code TFOX2024 for $200 off.

The Compliance Week 2024 Preview Podcast series is a production of the Compliance Podcast Network. Compliance Week is the sponsor of this series.

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Compliance Week Conference Podcast

Compliance Week 2024 Speaker Preview Podcast – Gwen Hassan on Navigating Your Compliance Career

In this episode of the Compliance Week 2024 Preview Podcasts series, Gwen Hassan discusses some of her presentations at Compliance Week 2024, “Navigating Your Compliance Career.” Some of the issues she will discuss in this podcast and her presentation are:

  • Turning opportunities into roadblocks
  • Compliance across industries and
  • Hearing about AI, Compliance, and other cutting-edge topics this year.

I hope you can join me at Compliance Week 2024. This year’s event will be held April 2-4 at The Westin Washington, DC, Downtown. The line-up for this year’s event is first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event, offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 19th year, join 500+ compliance, ethics, legal, and audit professionals who gather to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. Compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs, among many others, to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 80+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from panels on leadership, fraud detection, confronting regulatory change, abiding by cross-border rules and regulations, and the always favorite fireside chats.
  • Bring actionable takeaways to your program from various session types, including cyber, AI, Compliance, Board obligations, data-driven compliance, and many others, for you to listen, learn, and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. As an extra benefit to listeners of this podcast, Compliance Week is offering a $200 discount on the registration price. Enter the discount code TFOX2024 for $200 off.

The Compliance Week 2024 Preview Podcast series is a production of the Compliance Podcast Network. Compliance Week is the sponsor of this series.

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Corruption, Crime and Compliance

Alex Cotoia on Compliance with The Uyghur Forced Labor Prevention Act

On December 31, 2021, President Joseph R. Biden, Jr., signed the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the People’s Republic of China (“PRC”). Among other things, the UFLPA creates a rebuttable presumption that all goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in Xinjiang, or by entities designated for inclusion on the UFLPA Entity List, are prohibited from entry into the United States. To overcome the presumption, entities are required to demonstrate, by “clear and convincing evidence,” that such imports were not mined, produced, or manufactured in whole or in part by forced labor.

In this episode, Mike and Alex discuss practical steps to comply with the UFLPA.

  • The Uyghur Forced Labor Prevention Act, enacted by Congress, establishes a presumption that goods from Xinjiang are tied to forced labor. Importers must prove otherwise by providing extensive documentation, such as invoices, packing slips, and billing information, to demonstrate the origin of the goods and ensure compliance with the law.
  • The UFLPA has led to a significant increase in enforcement by CBP, resulting in the detention of billions of dollars worth of commodities. This heightened scrutiny has prompted global companies to prioritize robust ethics and compliance programs to mitigate the legal and economic risks associated with forced labor.
  • Compliance with the UFLPA requires importers of record to furnish CBP with clear and convincing evidence that their goods were not produced using forced labor. This evidence includes supply chain tracing information, wage and payment records, credible audits, and attestations from every entity involved in the production process.
  • Chinese entities have been known to employ deceptive practices to avoid detection and documentation requirements. This includes creating separate companies outside the Uyghur area and providing misleading information to purchasers. Due diligence and a thorough investigation of beneficial ownership are crucial to ensuring compliance.
  • CBP’s operational guidance for importers, published in 2022, provides essential information on navigating the complexities of the UFLPA. Importers should familiarize themselves with this guidance and engage in one-on-one discussions with their suppliers to communicate expectations and ensure compliance.
  • The UFLPA places a significant burden on organizations relying on imports from China, as they must provide extensive documentation and meet the clear and convincing evidence standard. Failure to meet these requirements can result in the detention of goods, leading to supply chain disruptions and potential financial losses.
  • Clear Channel, the former Chinese subsidiary of Clear Media, faced charges related to bribery violations. The bribes included expensive gifts, entertainment, and travel given to influence contract renewal negotiations with Chinese government officials. Clear Media engaged in deceptive practices, including falsifying payments and creating false invoices, to fund these illegal payments.

Resources:

Alex Cotoia on LinkedIn | Email

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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FCPA Compliance Report

FCPA Compliance Report – Nick Gallo on The Ethics and Compliance Optimization System

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes back Nick Gallo, co-CEO at Ethico, to discuss its Ethics and Compliance Optimization System.

Nick Gallo, co-CEO of Ethico, is a seasoned professional with a robust background in ethics and compliance, and a key player in the development and promotion of Ethico’s ethics and compliance optimization system. Gallo’s perspective on the topic of ethics and compliance optimization systems is shaped by his belief in a comprehensive, integrated approach to managing compliance efforts. He sees this system as a next-generation tool that interacts with other data pools, generating more analytics and insights. His experience has led him to advocate for a centralized repository for various types of business information, which can be accessed by compliance teams for better visibility across all data silos within an organization. Gallo also stresses the importance of automation and integration to eliminate manual and repetitive tasks, allowing compliance professionals to focus on more strategic and value-added activities.

 

Key Highlight:

  • Creating a centralized system for streamlining ethics and compliance
  • Why compliance needs a centralized data system for compliance professionals
  • The prevalence of retaliation in organizations
  • Leveraging data for proactive risk mitigation

Resources:

Nick Gallo on LinkedIn

Ethico

Ethics and Compliance Optimization System

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.