Categories
Innovation in Compliance

Strategic Compliance in Regulated Industries with Kerri Reuter

Innovation comes in many areas, and compliance professionals must be ready for and embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, Tom visits with Kerri Reuter, AVP, Legal Counsel at SageSure.

Reuter shares her extensive law, compliance, and athletics background, including her journey from being a volleyball player to her professional career in the insurance industry. The discussion covers SageSure’s business operations as a managing general agency (MGA) and the importance of collaboration and strategic thinking in her role. Reuter also highlights the significance of robust compliance programs in regulated industries, the implementation of the Athennian tool for corporate governance, and future growth plans, emphasizing the need for efficiency and forward-thinking in compliance and legal departments.

Key highlights:

  • Reuters’ Academic and Professional Journey
  • The Business of SageSure
  • Lessons from Volleyball: Skills in Professional Life
  • Regulatory Compliance in the Insurance Industry
  • Leveraging Athennian for Corporate Governance
  • Future Vision and Industry Involvement

Resources:

SageSure on LinkedIn

Kerri Reuter on LinkedIn

SageSure Website

Athennian Website

Categories
Red Flags Rising

Red Flags Rising: S01 E08 – Responding to Congressional Inquiries

Mike & Brent react to recent media reports of several congressional committees demanding information from U.S. companies. They revisit their March 14, 2024, NYU PCCE blog post, “”Expect Some Illumination”: A Fresh Look at U.S. Congressional Hearings in the Era of Sanctions and Export Controls as the New FCPA” (01:21), then discuss common pitfalls to avoid when providing information to Congress, including the importance of thinking critically about how your data could be interpreted and used by Congress (02:28), how information provided by Congress can be shared across the U.S. federal government (03:38), the danger of being distracted by political theater (04:13), the value of having a “red team” (or “blue team,” depending on your political leanings) vet your data with hostile eyes before sending data to Congress (06:48), anticipating and preempting difficult questions that the data might raise (08:06), keeping in mind the geopolitical context (09:05), ensuring that investor relations and communications coordinate with legal and compliance regarding public statements (10:30), and the oversight role of boards of directors (12:49). They conclude with another installment, still by popular demand, of Brent Carlson’s “Managing Up” (14:05).

Resources: 

Mike & Brent’s Prior NYU PCCE Post

Brent LinkedIn

Mike LinkedIn

Mike & Brent’s “Fresh Looks” Series

Categories
Blog

Upping Your Game – Compliance Moves into the 2030s

On February 10, 2025, the Trump Administration suspended investigations under and enforcement of the Foreign Corrupt Practices Act via Executive Order. Many compliance professionals have since wondered what this will mean for corporate compliance programs. Hui Chen, in a blog post entitled Pause in FCPA Enforcement: Crisis or Opportunity?, said, “Many in the compliance world have expressed lament, concerns, and anger. Understandably so. This may feel like an existential crisis for an industry so dependent on enforcement as its raison d’être. Yet, in every crisis, there is an opportunity. This is no exception.” She stated, “We will have the opportunity to find out which companies do not believe they need to engage in bribery to be competitive. But we will also see companies recalibrate their risk tolerance not because the door to foreign bribery has been wedged open, but because their past fear-driven strategy resulted in a sometimes overly narrow view of corporate risk and responsibility in this space.” She listed three key areas to start, the third being “it’s time to up your game.”

I agreed wholeheartedly with Chen. Inspired by Chen, I wanted to write a book for compliance professionals about how they could think through ‘Upping Their Game’ using currently existing Generative AI (GenAI) tools to improve their compliance programs dramatically. It all starts with the precept from Carl Hahn, “To me, the animating reason for our compliance program was to deliver business value. And that was my proposition on day one. It is a positive business-forward proposition based on returning on investment, returning value to the business, being part of the business strategy, enabling the achievement of strategic goals, and enabling the company to successfully deliver to its customers, investors, stakeholders, and employees.” As compliance professionals, it is critical to recognize that this moment is not merely about incremental improvements. The Trump Executive Order brings to the compliance profession a rare inflection point where revolutionary technological advancements, if harnessed strategically, can elevate our profession to a new level of effectiveness, efficiency, and organizational value.

Once reliant on manual oversight, reactive reporting, and periodic audits, compliance monitoring is evolving into a proactive, real-time capability empowered by sophisticated AI technologies. Compliance professionals historically functioned as gatekeepers, viewed as necessary but inconvenient barriers to business velocity. But now, driven by AI, compliance stands poised to shed that restrictive image, embedding directly into core operational workflows and thus shifting from gatekeeper to integral business partner.

Today, the cutting edge of compliance is driven by two primary strands of AI: predictive analytics, leveraging machine learning, and GenAI. Each has distinct capabilities, but combined, they represent a powerhouse able to address the vast majority of traditional compliance challenges and emerging risks. At its core, compliance seeks to identify, manage, and mitigate risks. Traditionally, this has meant looking backward, investigating past issues, and reacting to problems after they occur. AI fundamentally shifts compliance from this rearview mirror perspective to a forward-looking, predictive posture. Machine learning technologies empower compliance officers to train AI models on vast quantities of historical data, teaching systems to recognize patterns and indicators that suggest elevated risk in real-time.

Today, a compliance officer can use predictive analytics to tag transactional data by risk category, identifying potential bribes, improper payments, fraud, conflicts of interest, and sanctions violations. With these capabilities, compliance teams can proactively identify, isolate, and remediate issues before they escalate, significantly reducing organizational exposure and regulatory risk.

This shift from reactive to proactive risk management also enhances compliance agility. Organizations equipped with AI-powered monitoring can swiftly pivot to address new regulatory developments or emerging business risks. Because AI can integrate and analyze data in real-time from diverse sources, such as financial records, employee communications, operational metrics, and third-party data, the organization is positioned to respond to regulatory inquiries swiftly, accurately, and effectively, thus greatly enhancing compliance resilience.

AI offers a transformative capacity to integrate compliance directly into essential business processes by embedding compliance directly into an organization’s operations. Andrew McBride’s approach is termed the “Holy Grail” for compliance professionals who seek to seamlessly embed compliance responsibilities within operational workflows, enabling employees to carry out compliance tasks without interrupting their regular business activities.

For all these reasons and more, I am thrilled to announce the publication of my latest book, Upping Your Game: How Compliance and Risk Management Move to 2030 and Beyond. The compliance function is uniquely situated to lead the management of risk going forward, and in this book, I provide every compliance professional with key tactics, concepts, and strategies to move forward with GenAI today to answer the call to Up Your Game. Each chapter is dedicated to one area of a compliance program: risk management, third parties, training, chatbots, and embedded compliance. I provide key lessons for compliance professionals in each chapter and a case study on how one or more companies have created GenAI tools that can be adapted for compliance. Each one of these strategies meets Hahn’s precept to enhance business value.

I  interviewed some of the top thinkers on GenAI in the compliance field for this book. Contributors included Vincent Walden, CEO of konaAI, a global, AI-driven technology company focused on anti-fraud, anti-corruption, and compliance risks. Matt Galvin, co-founder of Gentic Global Advisors. Carl Hanh, co-founder of Gentic Global Advisors. Dr. Hemma Lomax, Deputy General Counsel, Vice President, Global Head of Ethics and Compliance at Docusign. Jag Lamba is the founder and CEO of Certa. Eric Sydell is a co-founder and CEO of Vero AI.

I hope you check out the book and use it as a basis for Upping Your Game going forward. KonaAI, a leading data analytics firm, sponsored this book.

You can purchase a copy of the book on Amazon.com.

Categories
Corruption, Crime and Compliance

[Replay] Four Sanctions Cases That Everyone Should Know

How prepared is your organization to handle the evolving landscape of sanctions compliance? In this Corruption, Crime, and Compliance episode, Michael Volkov dives into critical sanctions compliance cases and their implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of third-party liability, supply chain risks, and the dangers of inadequate compliance measures, offering valuable insights into how companies can proactively avoid similar pitfalls.

Cases discussed:

  • British American Tobacco (BAT): The company faced a staggering $629 million settlement for circumventing North Korean trade sanctions. This case illustrates how corporate prosecutions are evolving to resemble Foreign Corrupt Practices Act (FCPA) cases, emphasizing the growing scrutiny of multinational corporations.
  • Epsilon Electronics: This case clarifies companies’ liabilities when third-party distributors divert products to prohibited countries, such as Iran. Even if the company had no direct involvement in the diversion, it still bears responsibility, underscoring the importance of diligent monitoring of distribution channels.
  • ELF Cosmetics: The company received a $1 million fine for importing goods containing materials sourced from North Korea. This case underscores the critical importance of conducting thorough supply chain due diligence to ensure compliance with international sanctions.
  • Murad LLC: This case focuses on post-acquisition compliance failures, demonstrating the urgent need for thorough pre- and post-acquisition audits. These audits are essential to uncover potential sanctions violations and ensure that newly acquired companies adhere to compliance standards.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Links to the four cases: British American Tobacco | Epsilon Electronics I Elf Cosmetics | Murad LLC

A Framework for OFAC Compliance Commitments (May 2019)

Categories
Daily Compliance News

Daily Compliance News: April 21, 2025, The Tribute to Pope Francis 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. Yesterday, Trump rolled back almost all tariffs he had imposed 48 hours earlier. We look at four stories on that issue from the compliance angle.

Top stories include:

  • China built a Nepali airport through corruption. (NYT)
  • US banks urged to pull from Chinese securities offerings.  (WSJ)
  • Binance gets compliance. (Bitcoin.com)
  • Jaime Dimon says to tighten up meetings. (FT)
Categories
Compliance Tip of the Day

Compliance Tip of the Day – The Role of Supply Chain and Compliance in Tariffs

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.

In this episode, we consider how compliance can support your company’s Supply Chain in this era of tariff hikes and their suspensions.

Categories
Blog

Tariff Week, Part 5 – The Supply Chain and Compliance in the Age of Trump Tariffs

We conclude our 5-part series on the macroeconomic implications of President Trump’s recent tariff hikes and suspensions. Business leaders and compliance professionals are grappling with navigating this unprecedented landscape, and understanding the nuances of this evolving situation is crucial for corporate strategy and compliance preparedness. For today’s concluding Part 5, we consider how compliance can support your company’s supply chain in this era of tariff hikes and their suspensions.

Today’s discussion is based on the Harvard Business Review (HBR) article entitled The Tariff Wars Just Upended Your Supply Chain. Here’s How to Adapt by Willy C. Shih and Veronica Chua. By adapting this article for a compliance audience, I hope to show compliance professionals that the complexities introduced by recent tariff fluctuations are not confined to supply chain managers alone; compliance professionals are also grappling with unprecedented challenges. Understanding and responding to these challenges fortifies your compliance framework and empowers your business to adapt swiftly and smartly.

Lesson 1: Precision and Preparedness with Documentation

Supply chain disruptions underline the critical importance of maintaining accurate country-of-origin documentation. Tariff wars remind compliance professionals that documentation must not be treated as a mere formality. Rigorous attention to the accuracy and completeness of documentation mitigates risks of customs delays, penalties, or even seizure of goods. For instance, when President Trump’s administration suddenly eliminated the de minimis exemption, chaos ensued due to inadequate preparation for increased tariff documentation and customs scrutiny​.

Compliance professionals must proactively ensure thorough, timely, and precise documentation, verifying every link in the supply chain. Enforcing rigorous documentation standards gives your organization the agility needed during sudden regulatory shifts.

Lesson 2: Strategic Location Assessment and Risk Management

The article stresses that managers must reconsider their manufacturing locations strategically, examining feasibility, costs, and potential alternatives​. Compliance professionals play an instrumental role by assessing regulatory risks tied to specific locations and advising management on tariffs, customs compliance, local regulatory changes, and potential geopolitical disruptions.

Your role extends beyond merely following guidelines; you’re a strategic advisor who helps your business navigate complex global trade scenarios. The heightened tariff environment necessitates proactive, detailed compliance risk assessments, ensuring location decisions align with long-term business resilience and regulatory expectations.

Lesson 3: Enhancing Trade Bloc Awareness

Shih and Chua suggest revisiting trading bloc strategies, emphasizing a move toward diversified sourcing and regionalization. The economic implications of retaliatory tariffs underscore that overdependence on specific markets can significantly amplify compliance risks​.

Understanding international trade agreements, regional regulations, and bloc-specific requirements is vital as a compliance professional. Guiding your organization towards a diversified sourcing model reduces susceptibility to single-market fluctuations and enhances your regulatory compliance framework, creating more robust operational resilience.

Lesson 4: Supporting Infrastructure Modernization

A significant lesson from recent disruptions is that the existing U.S. infrastructure for customs and tariffs is severely strained under sudden regulatory shifts. The elimination of the de minimis exemption demonstrated glaring inefficiencies and capacity shortfalls, notably overwhelming customs operations at airports​.

Compliance professionals can play a crucial advocacy role by supporting and lobbying internally for investment in infrastructure modernization. Championing advanced technological systems and automated compliance solutions improves customs clearance processes, reduces human error, and accelerates the flow of goods through complex tariff environments. Your forward-looking compliance perspective keeps the business agile and protects it from potentially severe operational disruptions.

Lesson 5: Anticipating the Ripple Effects of Regulatory Changes

The proposed Section 301 fees exemplify unintended consequences arising from regulatory changes. By failing to account for standard container shipping rotations, proposed tariffs significantly disrupted logistics plans and increased costs for exporters, particularly in agriculture

The lesson for compliance professionals is clear: anticipate and evaluate broader implications beyond immediate regulatory compliance. Conduct scenario planning and impact assessments, forecasting regulatory ripple effects throughout the supply chain. Your predictive compliance strategies, including regular horizon scanning, ensure that your business remains compliant and strategically prepared for operational continuity.

Supporting Your Supply Chain Through Turbulent Times

Compliance professionals are key to navigating the complexities and uncertainties introduced by tariff wars. Your strategic input is not merely about adherence to rules; it is about understanding and mitigating risk, anticipating regulatory shifts, and providing strategic advice to senior leadership.

During these volatile times, compliance is elevated from a back-office function to a critical strategic partner in global operations. By taking charge of meticulous documentation, rigorously assessing location-related risks, understanding trade bloc dynamics, supporting infrastructure advancements, and anticipating the ripple effects of regulatory changes, compliance professionals safeguard their companies and help guide them confidently through the stormy waters of tariff fluctuations.

Moreover, compliance’s value lies in preparedness and strategic anticipation. The unpredictable landscape highlighted by the current tariff war emphasizes why proactive compliance is not merely advisable but imperative. Companies that leverage their compliance teams’ strategic capabilities will find themselves uniquely positioned to weather the storms of international trade and capitalize on the opportunities these shifts create.

As the HBR article underscores, compliance and operational leaders must collaborate closely to effectively handle the shocks from tariff wars. Embrace this partnership as an opportunity. In uncertain times, your role as a compliance professional becomes pivotal, not just to manage risks but to lead strategically, enabling your business to adapt, thrive, and emerge stronger in a challenging global trade environment.

Categories
Compliance Tip of the Day

Compliance Tip of the Day – Compliance Lessons from the Front Lines

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.

In this episode, Tom Fox explores the research showing that some companies have weathered trade wars better than others.

Categories
2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 50 – The Tariffs Tariffs Tariffs 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:

  • Trump is redefining what corruption is. (Axios)
  • The pain of doing business with the Trump Administration. (FT)
  • The fired DOJ lawyer accused the current DOJ leadership of corruption. (AP)
  • 8 arrested in Huawei corruption probe. (Bloomberg)
  • Whistleblowers awarded $6.7 million against Texas AG. (Houston Chronicle)
  • New Tariffs Promise Increased False Claims Act Scrutiny on Importers and Other Companies in the Import Chain (Gibson Dunn)
  • Justice Department Scales Back Crypto Enforcement (WSJ)
  • DOJ Monitorship Policy Disappears (Radical Compliance)
  • Navigate Career Chaos: 5 Steps to Find Clarity Now (Psychology Today)
  • Woman arrested after accidentally texting sheriff’s department instead of drug dealer (KKTV)

 

Resources:

Kristy Grant-Hart on LinkedIn

Prove Your Worth

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Rotary Voices of Kerrville

Rotary Voices of Kerrville – Navigating Professional and Community Service with Clint Morse

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 Rotary Club Program Chair Clint Morse about his professional career and longstanding involvement with the Rotary Club.

Clint shares his journey from attending the University of Texas Law School and joining the Navy’s JAG program during the Vietnam War to practicing labor law at prestigious law firms such as Andrews Kurth and Ogletree Deakins. Clint also discusses his move to Kerrville, Texas, in 2015 and his impactful work with the local Rotary Club, including his role as program chair and his efforts to bring diverse speakers to the club. Clint emphasizes the importance of community service over business networking in Rotary and reflects on some meaningful projects, including basketball tournaments and Salvation Army fundraising. He also discusses the balance required in inviting speakers and maintaining non-political stances within the Rotary Club. The conversation concludes with Clint sharing what Rotary means to him, highlighting the community service opportunities and the lasting friendships formed.

Highlights include:

  • Clint Morse’s Professional Journey
  • Joining Rotary: Challenges and Triumphs
  • The Role of a Speaker Chairman
  • The Personal Impact of Rotary

Resources:

Rotary Club of Kerrville

Rotary District 5840

Rotary International