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Compliance Tip of the Day

Compliance Tip of the Day – A Personal Operating System for Compliance Professionals

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 look at the importance of a personal operating model for compliance officers.

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Corruption, Crime and Compliance

[Replay] The Boeing Plea Agreement

This week, we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast.

Have you heard of the recent controversies around the Boeing 737 MAX and its safety? Have you wondered what is being done about its concerns? In this episode of Corruption, Crime, and Compliance, Michael Volkov delves into the latest developments in the Boeing 737 MAX case, highlighting the recent plea agreement proposed by the Department of Justice (DOJ). The Boeing 737 MAX case took another dramatic turn. On July 24, 2024, the Department of Justice filed a proposed plea agreement with Boeing with the United States District Court for the Northern District of Texas. Under the Plea Agreement, Boeing will plead guilty to the original information filed in 2021 with the Deferred Prosecution Agreement (“DPA”). The discussion focuses on Boeing’s alleged failure to implement adequate compliance measures, leading to significant risks and violations and the case’s ongoing legal and ethical implications. Tune in to hear a detailed analysis of the complexities and legal ramifications of Boeing’s recent plea agreement and what it means for corporate compliance and accountability.

You’ll hear him talk about:

  • Certification Issues: Boeing failed to ensure the accuracy of its 737 MAX certifications, risking false certifications to the FAA.
  • DOJ Plea Deal: Boeing agreed to plead guilty to conspiracy to defraud the U.S., facing opposition from victims’ families who find the resolution insufficient. The plea agreement, which has been filed under Federal Rule Criminal Procedure 11(c)(1)(C), requires the Court to approve and accept the deal. The Court can reject the plea deal and require the parties to renegotiate the terms.
  • Victims’ Rights: The proposed resolution has been controversial because of the opposition of the families of the victims, who have opposed the plea agreement and general disposition of DOJ’s investigation and prior resolutions as insufficient to vindicate the public interest and their rights as victims of Boeing’s malfeasance
  • Compliance Failures: Boeing breached its DPA by not implementing effective compliance controls, particularly in safety and quality processes.
  • Independent Monitor: Boeing will be monitored for three years and must invest $455 million in compliance and safety improvements.
  • Ongoing Challenges: Boeing’s anti-fraud measures still have gaps, with broader implications for industries where safety is critical.

Resources:

Michael Volkov on LinkedInTwitter

The Volkov Law Group

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Daily Compliance News

Daily Compliance News: March 24, 2025, The ABC Task Force 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:

  • UK, France, and Switzerland launch the ABC task force. (WSJ)
  • How resilient is your power supply? (BBC)
  • China targets ‘petty’ corruption. (WSJ)
  • Is the Former Argentinian President banned from the US for corruption? (Buenos Aires Times)
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FCPA Compliance Report

FCPA Compliance Report – Navigating the Complexities of FTO Designations and Compliance in Mexico and Latin America

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Tim O’Toole and Matt Ellis from Miller & Chevalier Chartered to discuss the significant implications of President Trump’s executive order designating Mexican drug cartels as foreign terrorist organizations (FTOs).

Tim and Matt elaborate on the heightened compliance risks and operational challenges now faced by companies operating in these regions. The conversation delves into the legal distinctions between Specially Designated Nationals (SDNs) and FTOs, the broad-ranging impact on industries such as agriculture and logistics, and the urgent need for robust risk assessment strategies to mitigate civil and criminal liabilities under U.S. law. They also explore the broader Latin American context and potential collateral consequences for U.S. and Latin American companies amid anticipations of increased regulatory scrutiny and enforcement actions. The discussion concludes with timely observations on recent U.S. Treasury directives aimed at curbing cartel money laundering activities, showcasing the lengths the administration is willing to go to combat these criminal enterprises.

Key highlights:

  • Executive Order and FTO Designation
  • Heightened Risks for Companies in Mexico
  • Complexities of Cartel Influence in Mexico
  • Risk Management Strategies for Companies
  • Broader Implications for Latin America
  • Potential Weaponization of FTO Designation
  • Corporate Compliance and Human Rights

Resources:

Designation of Cartels as FTOs Creates Heightened Risks for Companies Operating in Latin America

Miller & Chevalier

Tim O’Toole

Matt Ellis

Tom Fox

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Blog

Compliance Leadership Week: A Personal Operating System for Compliance Professionals

This week, we begin a five-part exploration of leadership for compliance professionals. All of this week’s blog posts will be based on articles from McKinsey & Company, and all authors are with McKinsey. I will look at individual leadership issues, compliance team leadership issues, and issues for a Chief Compliance Officer (CCO) or compliance professional for greater corporate matters. We begin our exploration by considering individual leadership issues for compliance professionals. Today’s (and tomorrow’s) blog posts are based on the article Warning: Upgrade your personal operating model by McKinsey authors Arne Gast and Suchita Prasad.

Compliance professionals are used to alerts and notifications reminding us to keep our organizational technology and systems up-to-date. Messages like “Update now or risk losing access” flash across our screens regularly, prompting immediate action to secure organizational infrastructure. But how often do we take such vigilant measures to update our personal operating systems and the personal models that guide our professional effectiveness and impact?

In today’s rapidly evolving corporate landscape, compliance officers face unprecedented challenges. Regulatory shifts, technological advancements, new business risks, and societal expectations are constantly in flux. To navigate these waves successfully, we must regularly revisit and recalibrate our personal operating models. Like any critical business system, your personal operating model comprises the choices you make regarding your priorities, the roles you fulfill, the allocation of your time, and the management of your energy.

The Importance of a Personal Operating Model for Compliance Officers

Just as outdated technology poses security risks to an organization, an outdated personal operating model can compromise your effectiveness as a compliance officer. Regularly updating your approach helps ensure alignment with organizational goals, regulatory demands, and professional growth opportunities. Yet, unlike device upgrades, no automatic alerts prompt these updates; compliance officers must generate internal notifications for reflection and action.

The Four Drivers of Your Personal Operating Model

To effectively refresh your compliance operating system, consider four critical drivers: priorities, roles, time, and energy. Each element is essential to your professional impact and resilience.

1. Priorities

Compliance leadership starts with setting clear, strategic priorities. Have you identified your compliance mandates? Do you understand the expectations and potential areas of overshooting or underperformance? Compliance mandates come from various stakeholders, including senior executives, board members, regulatory bodies, and external auditors. Clarifying these mandates and transparently communicating them is vital. Leaders must boldly determine which mandates to fulfill, manage stakeholder expectations, and consciously decide where strategic disappointments might be necessary, always within manageable bounds.

Consider a compliance officer entering a new organization. Initially hesitant to make sweeping changes to established protocols, a careful stakeholder review might reveal a clear mandate for significant compliance transformation. Recognizing and embracing these mandates positions you to effectively lead impactful change.

2. Roles

Effective compliance officers clearly define roles, prioritizing tasks uniquely suited to their capabilities and delegating responsibilities to leverage organizational strength effectively. Are you focusing only on critical compliance tasks that you can manage effectively? Are you building positive leverage by engaging competent team members?

For instance, overseeing critical internal investigations might require direct involvement, while day-to-day compliance monitoring could be delegated to well-trained compliance staff. Choosing where to apply your expertise maximizes your overall impact and builds robust organizational compliance capabilities.

3. Time

Managing time is a fundamental skill for compliance leaders. How effectively are you scheduling and structuring your time to handle critical compliance issues proactively rather than reactively? Establishing boundaries, creating productive rhythms, and thoughtfully redesigning meetings can dramatically increase compliance effectiveness.

For example, compliance executives often experience calendar overload with meetings, training sessions, and urgent crisis interventions. Reflecting on your meeting structure can streamline effectiveness, eliminate unnecessary gatherings, and improve the productivity and clarity of compliance communications. Clearer schedules allow space to manage emerging compliance risks and regulatory changes proactively.

4. Energy

Finally, maintaining and protecting your energy is crucial for sustained effectiveness and resilience. Compliance roles are demanding and often filled with high-pressure situations and complex problem-solving. Do you actively manage your health, nurture supportive relationships, and connect deeply with the purpose behind your compliance work?

A compliance leader in a multinational firm found himself stretched thin by constant international travel and demanding audits. Realizing his health was compromised, he committed to regular exercise, improved nutrition, and better sleep habits. Coupled with meaningful social connections and reflection on his professional purpose, these actions revitalized his energy, enhanced productivity, and deepened his commitment to his compliance leadership role.

Implementing Your Personal Operating System Upgrade

To systematically update your personal compliance operating model, consider enlisting accountability partners, colleagues, mentors, or trusted personal contacts—to ensure consistent reflection and action. Regularly scheduled reviews, akin to software updates, help maintain your personal operating system’s integrity and effectiveness.

As compliance officers, our effectiveness hinges significantly on our ability to adapt and respond proactively to evolving regulatory and business landscapes. While technology alerts remind us to upgrade our devices, we must generate our notifications, prompting essential personal model upgrades. Continually recalibrating priorities, clearly defining roles, efficiently managing time, and actively preserving our energy empower us to deliver impactful compliance leadership.

Maintaining an up-to-date personal operating model positions compliance professionals to proactively anticipate risks, effectively drive organizational compliance initiatives, and sustain long-term professional resilience. Regular updates to your personal compliance operating system are not merely beneficial; they are essential to your continued success and the broader success of your organization.

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Sunday Book Review

Sunday Book Review: March 23, 2025, The Hard-Boiled Edition

In the Sunday Book Review, Tom Fox considers books that interest the compliance professional, the business executive, or anyone curious. These could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. Today, we look at five books as an entrée into the hard-boiled detective fiction genre.

  1. The Maltese Falcon by  Dashiell Hammett
  2. The Long Goodbye by Raymond Chandler
  3. The Galton Case: A Lew Archer Novel by Ross Macdonald
  4. Sleep With Slander by Dolores Hitchens
  5. Indemnity Only by Sara Paretsky

Resources:

Classic Private-Eye Detective Novels: A Starter Pack in the New York Times

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Because That's What Heroes Do

Deep Space 9 – Episode 25: Penumbra and Beginning of the Final Arc

Get ready for an exciting new season of Because That’s What Heroes Do. This season, they take a deep dive into their favorite episodes of Deep Space 9. In this exploration, Tom and Megan are joined by Star Trek maven Alex Murphy (Murphy) from Montreal, a local historian, cinema, and TV fan who loves weird foreign films, horror, and obscure media. He has been watching Trek since he was a tiny punk, and it’s been a lifelong love. In this episode, the team concludes an exploration of the introduction to a new character for DS9’s final season.

Today, they review the episode Penumbra and dissect the beginning of the final story arc in Star Trek: Deep Space Nine. They elaborate on the writers’ excellent integration of various character storylines and delve into classic moments and Easter eggs. Key highlights include the Defiant docking sequence, Ezri Dax’s journey, and Quark’s humor. Significant discussions involve Worf and Ezri’s complicated relationship, the significance of the prophets’ messages to Sisko, and the portrayal of the Breen as formidable adversaries. The hosts also draw parallels between the spiritual dynamics in DS9 and real-world cultural structures, offering in-depth analysis and personal anecdotes. Whether you’re a serious Trekkie or new to DS9, this episode promises rich, thoughtful commentary and lively discussion.

Key highlights:

  • Easter Eggs and Nostalgia
  • Character Dynamics and Key Scenes
  • The Breen and Story Arcs
  • Final Thoughts and Reflections

Resources:

Megan Dougherty

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One Stone Creative

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Tom

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Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: March 22, 2025

Welcome to the Kerrville Weekly News Roundup. Each week, veteran podcaster Tom Fox and his colleagues Andrew Gay and Gilbert Paiz get together to go over a couple of their favorite stories from the past week from Kerrville and the greater Hill Country. Sit back, enjoy a cup of morning coffee, and listen in to get a wrap-up of the Kerrville Weekly News. We each consider two of our favorite stories and talk about the upcoming weekend’s events, which we will enjoy or participate in this weekend.

In this episode, Tom and Andrew return to examine some of the stories that caught their attention over the past week.

Stories include:

  • Fire in Kerrville
  • Crabapple Fire in Gillespie County
  • Michael Murphy in Frederiksberg
  • Workshops and Classes at MOWA
  • ‘Lost in Yonkers’

Resources:

Tom Fox on LinkedIn

Gilbert Paiz on LinkedIn

Andrew Gay on LinkedIn

Texas Hill Country Podcast Network

The Lead

Kerrville Daily Times

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending, March 22, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings you the compliance professional and the compliance stories you need to know to end your busy week. Sit back, and in 10 minutes, hear the stories every compliance professional should know from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • Cognizant counsel fired after Trump Order. (Law360) sub req’d
  • Is self-disclosure now a gamble? (Law360) sub req’d
  • Unilever fires activist CEO of Ben & Jerry’s. (BBC)
  • Business execs call Trump’s trade policy ‘fluid’. (NYT)
  • Ex-Credit Suisse head of risk and compliance fined in Switzerland. (Bloomberg)
  • DOJ enforcement outlook in healthcare under Trump. (Reuters)
  • 4 arrested in the EU Huawei scandal. (Politico)
  • Why CISOs quit. (Security Insights)
  • How bribery helped thieves steal thousands of iPhones. (WSJ)
  • Menendez wife trial to begin. (NYT)

You can check out the Daily Compliance News for four curated compliance and ethics-related stories each day here.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 48 – The March Madness 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:

  • Severance, your ‘Innie” and work-life balance. (NYT)
  • Difference in work generations. (HR Exchange)
  • Treasury flags $200 transactions at the border. (WSJ)
  • Schwartz fires Paul Weiss. (Law360)
  • Huawei bribery scandal hits EU. (BBC)
  • EU Omnibus Package: 10 things you should know about the proposed changes to key sustainability legislation (White Case)
  • Half of Compliance Officers Have Anxiety; Their Org Chart Might Be the Culprit (CCI)
  • Compliance Programs and Leaks (Radical Compliance)
  • Job Seekers Hit Wall of Salary Deflation (WSJ)
  • Florida police horse nabs man after wild chase over drug deal | ‘Get that bad man! ‘ (Fox 35 Orlando)

 

Resources:

Kristy Grant-Hart on LinkedIn

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