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Adventures in Compliance

The Case-Book of Sherlock Holmes – Unveiling Compliance Lessons in The Problem of Thor Bridge

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into the Sherlock Holmes collection The Case-Book of Sherlock Holmes  by Arthur Conan Doyle. It is final set of twelve Sherlock Holmes short stories by Arthur Conan Doyle first published in the Strand Magazine between October 1921 and April 1927. In this episode, we consider the story, the The Problem of Thor Bridge. In this story, Sherlock Holmes investigates a case involving a master jewel thief and Holmes investigative techniques. This story provides several valuable for the 21st century compliance professional by drawing parallels between Holmes’ investigative methodologies and contemporary compliance practices.

In this episode of ‘Adventures in Compliance,’ Tom Fox kicks off a new season by delving into the final collection of Sherlock Holmes stories, ‘The Casebook of Sherlock Holmes.’ This episode focuses on the importance of questioning assumptions, meticulous documentation, objectivity in investigations, and the use of data-driven insights. Additionally, Fox emphasizes fostering a culture that encourages employee whistleblowing and continuous improvement in compliance programs. Sponsored by Ethico, the episode also highlights tools and resources available for enhancing compliance leadership.

Highlights Include

  • The Problem of Thor Bridge
  • Investigative Lessons from Sherlock Holmes
  • Key Principles for Compliance Professionals
  • The Importance of Documentation and Technology
  • Fostering a Speak-Up Culture
  • Proactive Compliance and Continuous Learning

Resources

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

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

Check out the full 3-book series, The Compliance Kids on Amazon.com.

For an audio/video version of the Compliance Kids book, Speaking Up is AWESOME, contact Tom Fox.

 

Connect with Tom Fox

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Hidden Traffic Podcast

The Truth Behind Chinese Forced Labor Camps with Nury Turkel

Many of us may not realize the extent to which forced labor and unethical practices can influence the products we rely on every day. In this episode of The Hidden Traffic Podcast, Gwen Hassan and Nury Turkel explore the Uyghur Forced Labor Prevention Act (UFLPA) and the serious loopholes in global trade compliance. Their conversation reveals troubling gaps in the law, especially the de minimis rule, which allows items valued under $800 to bypass inspections when entering the U.S. Originally meant to streamline trade, this exemption has now become a tool for unchecked imports, including forced-labor goods and even illicit substances like fentanyl.

Nury highlights the urgency of corporate accountability, noting that UFLPA compliance is too often seen as a procedural task rather than a meaningful ethical commitment. He emphasizes that corporate leaders have the power to drive change, urging them to advocate for stricter enforcement and proactive measures across their supply chains. Nury’s perspective is clear: this isn’t just about regulatory adherence—it’s about embedding ethical practices that prioritize human rights and transparency in business operations.

Consumers, too, play a vital role in holding companies to higher standards. Increased public awareness and demand for responsibly sourced goods create a ripple effect, encouraging companies to be more transparent. Nury’s closing message to listeners is a reminder that each conscious choice contributes to a global movement against forced labor. By fostering accountability at every level, we can push toward a world where ethical practices are the norm, not the exception.

Resources:

Nury Turkel on the Web | LinkedIn |  X (Twitter) | Hudson Institute Events

No Escape: The True Story of China’s Genocide of the Uyghurs

Categories
Corruption, Crime and Compliance

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations

How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the Department of Justice over pervasive violations of the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) laws. Highlighting TD Bank’s systemic failures, Michael explores how its compliance and oversight lapses led to criminal conduct within its operations, making it a case study on the dangers of prioritizing growth over legal compliance. From failed AML programs to enabling money laundering on a massive scale, this episode sheds light on the regulatory crackdown TD Bank now faces.

Hear him discuss: 

  • TD Bank’s $3 billion penalty sets a new high for banking compliance cases. In yet another reminder of the scope of Justice Department enforcement powers and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act (“BSA”) and money laundering violations.
  • TD Bank’s internal culture sidelined AML compliance, leading to massive oversights, including unmonitored transactions worth $18.3 trillion from 2018 to 2024. 
  • TD Bank enforced a “flat-cost paradigm,” restricting the compliance budget, which prevented updates and adaptations needed to meet new risk levels.
  • TDBUSH pleaded guilty to causing TDBNA to fail to maintain an AML program that complies with the BSA and to file accurate Currency Transaction Reports (“CTRs”).
  • Despite multiple warnings from internal audits and third-party consultants, the bank maintained its flawed AML protocols without significant action.
  • TD Bank earned the ignominious record of being the largest bank in U.S. history to plead guilty to Bank Secrecy Act program failures and the first US bank to plead guilty to conspiracy to commit money laundering.   
  • With this settlement, TD Bank joins a list of high-profile compliance failures alongside companies like Wells Fargo and Wirecard, furthering the call for financial institutions to prioritize ethical compliance in their growth models.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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Daily Compliance News

Daily Compliance News: November 4, 2024 – The Shame of it All 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 business world stories: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

  • Warren rebukes DOJ over TD Bank settlement.   (WSJ)
  • The Bank of Israel uses shaming to fight money laundering. (TheJerusalemPost)
  • BDO is in hot water for failure to pay an arbitration award for wrongful termination. (FT)
  • Fat Leonard is to be sentenced. (SanDiegoPost)

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

Check out the full 3-book series, The Compliance Kids, on Amazon.com.

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FCPA Compliance Report

FCPA Compliance Report – The 2024 ECCP on Data-Driven Culture and Engagement

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox visits with Sam Silverstein on how compliance professionals should view the new DOJ mandate on using data to assess, manage, and improve corporate culture through data-driven compliance. The Culture Audit sponsors this podcast.

In this comprehensive discussion, Tom Fox and Sam Silverstein delve into the 2024 Update to the Evaluation of Corporate Compliance Programs (ECCP) by the DOJ. Released in September, this latest update emphasizes the importance of data analytics, culture, engagement, and trust in compliance programs. With a detailed breakdown of over 250 questions posed by the ECCP, Tom and Sam provide valuable insights on how companies can benchmark their compliance programs and prepare for potential investigations. They highlight the role of a culture audit in addressing the DOJ’s requirements, offering a detailed look into how organizations can measure and improve their compliance culture. This webinar educates compliance professionals on the latest DOJ expectations and provides practical tools and methodologies to enhance corporate compliance efforts.

Highlights in this episode:

  • Importance of Culture and Data Analytics
  • Leveraging Data for Compliance
  • Measuring and Improving Culture
  • Data-Driven Culture of Compliance
  • Understanding and Utilizing Culture Audit Data
  • Forward Steps for a Stronger Culture

Resources:

Culture Audit

Set up a call to discuss the Culture Audit, click here

Sam Silverstein and the Accountability Institute

Sam Silverstein on LinkedIn 

Tom Fox

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Sunday Book Review

Sunday Book Review: November 3, 2024 – The Books on Risk Edition

In the Sunday Book Review, I consider books that would interest the compliance professional, the business executive or anyone who might be curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me.

In today’s edition of the Sunday Book Review, we look at four top book risks for the compliance professional in November 2024.

  1. Against the Gods: The Remarkable Story of Risk by Peter L. Bernstein
  2. The Black Swan: The Impact of the Highly Improbable by Nassim Nicholas Taleb
  3. Risk: A User’s Guide by General Stanley McChrystal and Anna Butrico
  4. Risk: A Very Short Introduction by Baruch Fischhoff and John Kadvany

 

Resources:

Top Books To Read on Risk in 2024 in Dataminr.com

Categories
Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: November 2, 2024

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 will enjoy or participate in this weekend.

In this episode, Tom and Andrew are back to look at some of the things that caught their attention over the past week.

Stories Include:

  • Arts and Craft Fair
  • Blown Glass Mural Artist honored at Tivy High School
  • Kerrville Pets Alive needs foster parents
  • Cowboy Days in Fredericksburg
  • Hill Kerrville Car Fair
  • Vote on November 5

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 November 2, 2024

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of 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.

  • Alibaba settles with shareholders for $433MM. (WSJ)
  • How a BBC podcast led to the arrest of Mike Jeffries. (BBC)
  • AstraZeneca China BU President under investigation. (FT)
  • Trafigura faces $1bn hit for corruption in Mongolia. (Bloomberg)
  • Sri Lanka to probe corruption in tanker disaster. (Al Jazeera)
  • UBS stuck in yet another Mozambique tuna bond investigation. (Bloomberg)
  • It turns out audit reports do matter. (WSJ)
  • JP Morgan set to settle several SEC enforcement actions. (Reuters)
  • Modern slavery stopped on the Scottish trawler. (BBC)
  • Olympus chief fired for purchasing illegal drugs. (FT)

 

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Because That's What Heroes Do

Because That’s What Heroes Do: Deep Space 9 – Episode 16: Favor the Bold: End of The Beginning

Get ready for an exciting new season of Because That’s What Heroes Do. In this season, they take a deep dive into their favorite 15 episodes of Deep Space 9. In this exploration, Tom and Megan are joined by Star Trek maven Alex Murphy (Murphy) from Montreal, who is a local historian and cinema and tv fan with a love for weird foreign films, all things 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 reviews the start of a two-part ending of the first phase of the Dominion war with Favor the Bold.

In this episode, the hosts delve into ‘Favor the Bold,’ the penultimate episode of the Siege Arc in Star Trek: Deep Space Nine. They discuss pivotal moments and character developments as the Dominion tightens its grip on the station, forcing Sisko and his crew to adapt their strategies. Key character interactions include Kira under Dominion rule, Odo’s complex relationship with the female changeling, and the emotional growth of Rom and Quark. The episode also introduces new characters and sets the stage for the concluding chapter in ‘Sacrifice of Angels.’ The hosts explore themes of loyalty, sacrifice, and the moral complexities faced by the characters, offering deeper insights into the larger narrative of DS9.

Key Highlights:

  • Key Characters and Plot Points
  • Character Dynamics and Relationships
  • Odo and the Female Founder
  • Dukat and Ziyal’s Relationship
  • Final Thoughts and Reflections

Resources:

Megan Dougherty

LinkedIn

One Stone Creative

Tom

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Twitter

LinkedIn

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Compliance Tip of the Day

Compliance Tip of the Day: Creating, Strengthening, and Maintaining Corporate Culture – Lessons from The Mummy

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.

What lessons does Boris Karloff’s The Mummy provide in creating, strengthening, and maintaining corporate culture?