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Using GenAI to Make Small Transformations

A recent article entitled Generate Value From GenAI With ‘Small t’ Transformations by Melissa Webster and George Westerman caught my attention. The authors posited that business leaders get real value from large language models by working their way up the risk slope and building the foundation for larger future transformations. However, they came up with an interesting strategy to test their question. They wrote, “As business strategists, we wanted to see what generative AI could add to our work. We explored this question through experiments on different aspects of the strategy creation process. In each experiment, we put a realistic strategy question to ChatGPT, followed by a lengthy back-and-forth to refine the initial responses. The intention was to understand how the tool can support ideation, experimentation, evaluation, and the building of stories—and where it falls.”

Basically, they used ChatGPT and generative AI (GenAI) to create and refine the strategy. I found this approach very interesting for the compliance professional. From this approach, they learned lessons in three uses applicable to the compliance professional.

  1. GenAI in Tasks That Are Common to Individuals in Many Roles
  2. Specialized GenAI for Compliance Professionals
  3. Enhancing the UX

Common Tasks. Compliance professionals can use large language models (LLMs) in ways that are useful to many compliance roles, such as writing, synthesizing information, generating imagery, and documenting meetings. GenAI’s near-ubiquitous nature can have a real impact on your compliance function. You can buy or create integrated tool sets that link generative AI to other functions that compliance professionals typically perform. Benefits vary by use and user, with individual initiative-taking and prompting skills influencing the value they derive.

Consider adding compliance-specific intelligence by training models on terminology and information that are proprietary to the company. For example, the authors point to the “Global consulting firm McKinsey built Lilli, [which built] a platform that links generative AI to its intellectual property from over 40 internal sources. The effort involved significant technical hurdles; for example, the tool needed to be changed to read PowerPoint slides, one of the company’s main ways of communicating project information, but the platform is providing value. For instance, if a consultant has a question about green energy business models in less-developed economies, Lilli can quickly find and synthesize information from projects that have already studied the problem somewhere in the world. McKinsey has reported that the platform’s capabilities and robust employee education led to about 75% of employees actively using Lilli in less than a year, time savings of up to 30%, and substantially improved quality.”

McKinsey is not alone in developing these specialized models for the general workforce. The same approach would work for a compliance function.

Specialized GenAI for Compliance. In this category, the authors say that “companies working their way up the risk slope are developing generative AI capabilities to improve productivity and quality in specific job roles or business processes. There is less tolerance for unacceptable output here.” These GenAI resolutions “typically maintain a human in the loop, where employees interact with the tools and review the outputs rather than allowing the GenAI tools to make decisions or produce outputs automatically.” Moreover, such outputs would seem directly suited for the compliance function.

In the space adjacent to compliance, the world of corporate finance, the authors found that “finance teams are relatively late adopters of new technologies, with CFOs citing technology gaps, data concerns, and competing priorities as reasons for that lag.” What does that sound like? Many legally trained corporate compliance officers.

The authors cited, “One international energy company we studied created a tool using a mix of GenAI, traditional AI, and other algorithms to suggest mitigations or help rewrite an audit report. Other companies use generative AI to assist in drafting reports for audits or regulatory compliance. At Amazon, the finance function uses rules-based AI, machine learning, and LLMs to address tasks in fraud detection, contract review, financial forecasting, personal productivity, interpretation of rules and regulations, and tax-related work.” Such a tool could move compliance professionals from repetitive tasks to focus more on work involving critical thinking.

Enhancing the UX. The next step for GenAI in compliance is with its customers, i.e., corporate employees. Just as GenAI is transforming traditional customer service and retail engagement, it can do so for interactions by compliance and employees. Unlike traditional phone menus or robotic process automation (RPA) chatbots, GenAI enables dynamic, multilingual responses, enhancing customer experience while optimizing operational efficiency. Take the example of John Hancock, which has implemented AI-driven chatbots to manage routine inquiries, allowing human agents to focus on more complex customer needs. This shift improves response times, reduces costs, and increases employee efficiency. Now, apply that strategy to your employees.

Beyond text-based interactions, GenAI is expanding into voice-based customer engagement. Companies like Starbucks, Domino’s, CVS, and major banks are integrating AI-driven voice assistants with future applications that will likely include video-based interactions. Compliance can also use all of these strategies.

By pursuing small-t transformation, often with a human in the loop, as they build capabilities, your compliance team can enable the development of applications with higher value and risk. The authors list several actions a Chief Compliance Officer (CC) can take to generate transformation with generative AI.

  1. Identify key pioneers in your organization and develop your messaging. With generative AI, innovation often comes from “cyborgs”—early adopters who integrate the technology into their work and are motivated to use it to solve a problem for themselves or their customers. Use them to communicate your innovation vision.
  2. Assess your company’s current position on the risk slope. What are you already doing, and what would be the next level of complexity and reward? Look at opportunities in individual productivity, role-specific enhancements, and innovations in product or customer engagement.
  3. Consider scalability. The authors noted, “According to the head of AI at a large bank we spoke with, “the more stuff you do, the more stuff you find to do.”
  4. Secure management buy-in. Small-t innovations can help to make the value story real and make the case for investments that can reduce the perceived risk of larger opportunities.
  5. Investigate foundational investments. Some of the boldest use cases will require extensive investment in data cleansing, model training, and integration before they can be ready for a real-world test.
  6. Maintain a long-term perspective. “The transformative cases take longer to build the business case, test the models, change behaviors, etc.,” said Chris Bedi, chief customer officer at software company ServiceNow. “The challenge is not only technical but also leaders taking time to reimagine their future with big ideas.”

The bottom line is that while productivity gains are the expected and common benefits of applying GenAI to specialized roles and tasks in compliance, the technology’s true impact extends further. GenAI is fundamentally transforming what compliance professionals can achieve. GenAI is enabling innovations and reshaping traditional compliance processes by enhancing efficiency and expanding the realm of possibilities within various functions.

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Compliance Tip of the Day

Compliance Tip of the Day – How Compliance Can Leverage Agentic AI Systems

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 continue our exploration of Agentic AI by considering how compliance can leverage Agentic AI systems.

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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Daily Compliance News

Daily Compliance News: February 4, 2025, The Reframing not Retreating Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Consumer Financial Protection Bureau Ordered To Stop Work. (Forbes)
  • DEI-reframing, not retreating. (FT)
  • Trafigura and ex-COO were convicted of bribery. (Bloomberg)
  • How Binance is ensuring compliance. (CoinPedia)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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Hill Country Authors

Hill Country Authors Podcast – Uvalde’s Darkest Hour By Craig Garnett

Welcome to a new season of the award-winning Hill Country Authors Podcast, sponsored by Stoney Creek Publishing. In this podcast, Hill Country resident Tom Fox visits with authors who live in and write about the Texas Hill Country. In this episode, Tom visits Craig Garnett, publisher of the Uvalde Leader-New and author of the book Uvalde’s Darkest Hour, about the school shooting in Uvalde, Texas, and its fallout, which continues to resonate today.

This episode explores a perplexing case regarding active shooter preparedness and failures. The discussion centers around a specific school district that conducted active shooter training for law enforcement officers just two months before an event. Despite this, the response on the event day did not follow the trained protocols after the initial minutes. The Department of Justice issued a scathing report highlighting the unpreparedness of the district, which included issues such as non-locking doors, inadequate fencing, and the absence of a patrolling officer at the elementary school on the day of the incident. Critically, the active shooter protocol was not effectively implemented despite being documented by the school police department.

But more than simply a recitation of the failures of law enforcement, Garnett looks at the continued impact of the shooting on the survivors, the families of the victims, and, indeed, the entire community of Uvalde.

Key highlights:

  • Active Shooter Training and Preparedness
  • Failures on the Day of the Event
  • School District’s Shortcomings
  • Police Force and Protocol Issues
  • Gun Rights and Controls
  • Uvalde Today

Resources

Craig Garnett on LinkedIn

Uvalde’s Darkest Hour on Amazon.com

Uvalde Leader-News

Tom Fox

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Facebook

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LinkedIn

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Innovation in Compliance

Innovation in Compliance – Financial Literacy and Smart Investing with Kris Miller

Innovation comes in many areas, and compliance professionals need to not only be ready for it but 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, host Tom Fox is joined by Kris Miller, a fellow podcaster, author, and member of the C-Suite, to discuss her extensive background as a financial expert.

Kris shares her journey from starting as a paralegal to becoming a prominent figure in financial education, particularly focusing on living trusts and safe money strategies. She provides valuable insights into how individuals can ‘crash-proof’ their finances using tools like equity index annuities and index universal life policies. Kris underscores the importance of early financial planning and debunks myths surrounding investments, emphasizing the need for safe and sustainable financial practices. She also touches upon the significance of living trusts and asset protection in traditional estate planning. Kris’s mission is to educate millions on healthy money strategies, especially amidst current financial volatility. Kris discusses her podcast ‘Money 9-1-1,’ which covers health, wealth, and peace of mind, and her book ‘Ready for PREtirement: 3 Secrets for Safe Money and a Fabulous Future.’

Key highlights:

  • Mission to Educate on Financial Strategies
  • Living Trusts and Asset Protection
  • Insurance as an Investment Tool
  • Long-Term Health Care Solutions
  • Social Media Outreach and Podcast

Resources:

Kris Miller on LinkedIn

Money 9-1-1 Podcast

Ready for PREtirement on Amazon.com

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Blog

Building a Data-Driven Culture: A Compliance Imperative in the Age of AI

I recently read an article in the Sloan Management Review entitled “Building a Data-Driven Culture: Four Key Elements” by Ganes Kasari, founder and CEO at Tensor Planet. He posits that a data-driven culture is vital to success with AI projects, but shaping one involves many challenges. He suggests that learning how to build one from organizations that have made the journey engaging for employees is one approach to take. For compliance professionals, this is a critical issue. Compliance, risk management, and governance efforts may be ineffective if a company’s workforce does not instinctively turn to data when making decisions.

The Department of Justice’s (DOJ) 2024 Update on the Evaluation of Corporate Compliance Programs (2024 ECCP) has made it clear that compliance programs must be data-driven, proactive, and continuously monitored. But if an organization has not built a culture of data-driven decision-making, compliance will always be playing catch-up.

So, how do companies foster a data-driven compliance culture? Kasari says the answer lies in four key areas:

  1. Leadership Intervention
  2. Data Empowerment
  3. Collaboration
  4. Value Realization

Leadership Intervention: Setting the Tone from the Top

For a compliance program to be truly effective, proactive, and data-driven, leadership must take an active role in championing the importance of data in decision-making. Too often, executives fund compliance initiatives but delegate execution entirely to compliance and IT teams. The result? Employees still see compliance as someone else’s job rather than an integral part of business operations.

The DOJ has emphasized that compliance programs must have engaged leadership. That means:

  • Executives must communicate why data and AI are essential for compliance.
  • Leaders must use data themselves, modeling the behavior they expect from their employees.
  • Regular check-ins and accountability measures should ensure compliance is not just an IT issue but an enterprise-wide priority.

Concept in Action: Rewarding Compliance Innovation at DBS Bank

When DBS Bank launched its digital transformation initiative, CEO Piyush Gupta prioritized creating a culture that rewarded data-driven decision-making and innovation. In one case, an employee made a data-driven compliance decision, ultimately leading to a failed experiment. There was regulatory pressure to penalize the employee, but Gupta stepped in and awarded them instead—for trying, learning, and embracing the new compliance culture.

This kind of visible leadership support sends a powerful message: compliance isn’t just about avoiding penalties but also about building a smarter, more resilient organization.

Data Empowerment: Making Compliance Everyone’s Job

For compliance to be truly embedded in company culture, every employee, not just compliance officers, must be able to access, understand, and act on data.

This means focusing on three levels of readiness:

  1. Data Readiness – Ensuring high-quality data is available at the right time to the right people.
  2. Analytical Readiness – Training employees to interpret compliance data and make informed decisions.
  3. Infrastructure Readiness – Investing in AI-driven compliance tools, automation, and real-time risk monitoring systems.

Concept in Action: JPMorgan Chase and the DeepRacer Challenge

JPMorgan Chase wanted to upskill employees in AI and data analytics. Instead of boring compliance training sessions, the company introduced a global challenge using AWS DeepRacer, a competitive coding event where employees programmed autonomous vehicles to race.

Employees learned data analytics, AI programming, and machine learning principles while having fun. The result? Thousands of employees became data-literate, able to apply AI-driven insights to compliance, risk management, and fraud detection.

Collaboration: Breaking Down Compliance Silos

Too often, compliance sits in its bubble, siloed from business operations. However, in an AI-driven world, compliance must be embedded in every department, from finance and HR to product development and supply chain management.

A major barrier to compliance collaboration is language. Compliance teams often use technical jargon, while business teams use operational language. The result? Miscommunication, resistance, and confusion.

To fix this, compliance functions must invest in:

  • Cross-functional compliance training so business leaders understand compliance risks.
  • Compliance “translators”—employees who bridge the gap between compliance and business operations.
  • AI-powered compliance dashboards that translate risk into actionable business insights.

Concept in Action: Gulf Bank’s Data Ambassador Program

Gulf Bank wanted to embed data-driven compliance across its 1,800 employees. Instead of relying solely on compliance officers, the bank created a network of data ambassadors—employees across departments trained to champion compliance best practices.

The results were impressive: employees felt more ownership over compliance decisions, and the company saw a significant reduction in compliance violations.

Value Realization: Measuring and Celebrating Compliance Success

One of the companies’ biggest mistakes is treating compliance as a cost center rather than a value driver. Compliance isn’t just about avoiding fines—it’s about driving better business decisions.

To ensure compliance is seen as a competitive advantage, companies must:

  • Define clear KPIs to measure compliance impact.
  • Track and communicate compliance success stories internally and externally.
  • Tie compliance initiatives to tangible business outcomes (e.g., revenue growth, cost savings, enhanced brand reputation).

Concept in Action: AI-Powered Warehouse Compliance at a Logistics Firm

A cold chain logistics company struggled with inefficient warehouse scheduling, leading to regulatory fines and supply chain bottlenecks. The compliance team introduced an AI-driven scheduling system, analyzing weather data, shipment history, and supplier reliability to optimize deliveries.

The results?

  • 16% reduction in turnaround time
  • $1.2 million saved annually in avoided fines
  • Increased customer satisfaction

To celebrate this success, the company shared the story through internal newsletters, town halls, and webinars, ensuring that employees saw compliance as a strategic enabler rather than just a legal requirement.

Compliance in the Age of AI

The DOJ’s 2024 guidance has made it clear that compliance programs must be data-driven, proactive, and continuously monitored. But simply investing in AI tools isn’t enough. Companies must build a truly data-driven culture where compliance is instinctive, embedded, and embraced across all levels of the organization.

The key takeaways?

  1. Leadership must champion compliance—not just fund it.
  2. Compliance must be accessible, understandable, and actionable for all employees.
  3. Cross-functional collaboration is essential to break down compliance silos.
  4. Compliance success must be measured, celebrated, and tied to business impact.

In 2025 and beyond, companies that embed AI-driven compliance into their culture will not only avoid regulatory fines and penalties or even FCPA violations, but they will also gain a competitive edge in an increasingly complex business world.

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FCPA Compliance Report

FCPA Compliance Report – DeepSeek and the Recalibration of Risk with Mike Huneke and Brent Carlson

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Mike Huneke and Brent Carlson for a special two-part podcast series on DeepSeek’s bombshell AI advancements announced on President Trump’s inauguration day. In Part 1, they review the business and compliance implications, and in Part 2, they consider the Sputnik Moment that has occurred.

In Part 1, they consider the immediate and significant repercussions in both the business and compliance landscapes. Key topics include the economic and geopolitical ramifications of DeepSeek’s innovations, changes in export control policies, and the unique compliance challenges AI technology poses. The discussion also examines how corporations can recalibrate their risk frameworks, integrate high-probability standards, and leverage data analytics to handle millions of transactions in a global economy. Emphasizing the importance of comprehensive compliance programs, the episode provides actionable insights for compliance professionals navigating this evolving landscape.

Key highlights:

  • DeepSeek’s AI Breakthrough
  • Economic and Compliance Implications
  • Export Controls and Legal Concerns
  • Compliance Strategies and Risk Management
  • Training and Organizational Culture

Resources

Mike Huneke

Hughes Hubbard & Reed website

Brent Carlson on LinkedIn

A Fresh Look at US Export Controls and Sanctions

DeepSeek Finds US Export Controls at a New ‘Sputnik Moment’ in Bloomberg.Law

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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Compliance Tip of the Day

Compliance Tip of the Day – Introduction to Agentic AI for 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, 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 begin a look at Agentic AI and how it can be used in compliance.

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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Daily Compliance News

Daily Compliance News: February 3, 2025, The Division of Engagement and Compliance Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Congress says Nvidia chip flow to China should be stopped. (WSJ)
  • The CCO Departure Bonus. (Cosmos)
  • WVU replaces DEI with “Dept. of Engagement and Compliance”. (12WBOY)
  • Will Trump DOJ drop corruption charges against NYC Mayor? (Reuters)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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Corruption, Crime and Compliance

The New Era of Compliance — Generative AI, Data and Innovation

The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact? While its potential is undeniable, the road ahead is full of risks, challenges, and ethical concerns. Will AI drive efficiency and innovation, or will it create new vulnerabilities that companies must scramble to control?

In this episode of Corruption, Crime, and Compliance, Michael Volkov dives deep into the legal, ethical, and compliance challenges surrounding AI. He explores how businesses are navigating AI adoption, the risks they face, and the safeguards they must implement to protect themselves.

You’ll hear him discuss:

  • Why AI’s economic impact, while significant, may not match the transformative power of the internet
  • Goldman Sachs’ prediction that AI could add $7 trillion to global GDP over the next decade
  • The massive investments required to scale AI, from semiconductors and data centers to energy and infrastructure
  • How generative AI is reshaping industries by creating human-like content with limitless applications
  • The hidden dangers of AI, including misinformation, deepfakes, fraud, and identity theft risks
  • Why businesses are cautiously adopting AI while grappling with privacy, copyright, and security concerns
  • The importance of AI compliance programs to mitigate legal, ethical, and reputational risks
  • Best practices for companies to ensure AI-generated content is accurate, transparent, and responsibly used

Resources

Michael Volkov on LinkedIn | X (Twitter)

The Volkov Law Group