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FCPA Compliance Report

FCPA Compliance Report: Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance

In this episode, Tom Fox welcomes Mara Senn, founder and CEO of Ethakos, about her path from big law and a decade as a partner at Arnold & Porter to anti-corruption work at the Kleptocracy Initiative, investigations at the World Bank, and in-house leadership roles at Fortune 500 medical device and pharma companies.

Senn explains she built the Ethakos compliance investigations platform using “vibe coding” with Claude, reducing reliance on software engineers and enabling rapid product decisions. She describes Ethakos as AI-native and human-in-the-loop, designed around how compliance teams actually work, with cleaner data creation, configurable workflows, and features that automate painful reporting tasks (e.g., investigation updates) and first drafts of chronologies, interview outlines, and reports. Senn emphasizes audibility via logs and citations, advises starting AI projects with clear risk goals, and predicts AI will remove menial work so teams can cover more risks while becoming more data- and tech-forward. Contact options include ethakos.com, email, and LinkedIn.

Key highlights:

  • Why Build Ethakos
  • AI Native Platform Design
  • Solving Reporting Pain
  • Starting AI in Compliance
  • Avoiding Common AI Mistakes
  • Investigation Workflow Automation
  • Auditability and Regulator Proofing
  • Future of Compliance Teams

Resources:

Ethakos

Mara Senn on LinkedIn

Tom Fox

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To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠.

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AI Today in 5

AI Today in 5: August 31, 2026, The AI for Mental Health Treatment Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. AI implementation with compliance. (PharmExec)
  2. AI redefining regulation and compliance. (FinTechGlobal)
  3. AI on reading the body’s signals. (MedCityNews)
  4. Should you use AI for mental health treatment? (WSJ)
  5. Reimagining health care delivery through AI. (Cleveland)

For more information on using AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on ⁠Amazon.com⁠.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠.

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Blog

Odyssey Week: Leadership – Athena in the Boardroom: Independent Oversight and Counsel

Ed. Note: I was finally able to see the movie The Odyssey. To say it blew me away was an understatement. Even though it didn’t follow Homer’s work precisely or use ancient Greek, I still thought it was great cinema. Anytime you get people talking about the Greek classics, that is a win in my book. So check out the movie and enjoy it. Zendaya was great as Athena.

Athena does not row the ship. She does not lash herself to the mast, fight the Cyclops, navigate Scylla and Charybdis, or drag Odysseus’s crew away from every bad decision they seem determined to make. She is not in the trenches every day. She does not submit expense reports, approve vendors, review discount requests, or sit through the quarterly business review where someone explains why this deal is “strategic.” But Athena changes the journey.

She sees what Odysseus cannot see. She warns. She guides. She challenges. She protects. She appears at decisive moments when courage alone is not enough, and cleverness is about to become self-harm with better branding. That is why Athena belongs in the boardroom.

For corporate compliance, Athena represents independent oversight and wise counsel: the person, function, or governance body able to say, “That may win the deal, but it may also wreck the kingdom.” A compliance function that cannot challenge leadership is not Athena. Rather, it is simply decoration to meet a legal, statutory, or contractual requirement.

The Corporate Translation

Every company says it values compliance independence. The question is what that means when the business wants something. It is easy to celebrate compliance when compliance supports the decision already made. It is easy to invite the Chief Compliance Officer (CCO) to the meeting after the deal is signed, the press release is drafted, and the train has left the station with several questionable third parties in the dining car. That is not independence. That is archaeology.

Independent oversight means compliance has the authority, access, and resources to influence decisions before risk is accepted. It means the board hears directly from compliance. It means escalation does not depend on whether a business leader feels emotionally prepared for bad news. It means compliance can challenge high performers, powerful executives, and sacred business strategies without being treated as disloyal.

Athena does not exist to admire Odysseus. She exists to help him survive himself.

Access Is Not the Same as Influence

Many compliance officers technically have access to leadership. They attend meetings. They submit reports. They provide updates. They own several slides in the board deck, usually after cybersecurity and before “other business.” But access is not the same as influence.

Real access means compliance can raise concerns in a setting where they matter. It means there are private sessions with the board or audit committee. It means compliance can speak without management filtering, softening, or translating the message into something more comfortable. It means the board asks questions that go beyond “Any major issues?” which is the governance equivalent of asking a teenager whether school was fine.

The DOJ’s 2024 Evaluation of Corporate Compliance Programs (ECCP) focuses directly on whether compliance and control functions have autonomy and resources, including sufficient stature, sufficient staffing and resources, and autonomy from management, such as direct access to the board or audit committee. That is not a technical footnote. It is a central governance point. If the compliance function only reaches the board through management, the board may be hearing the music after someone else has adjusted the volume.

Authority Must Be Real

A compliance function without authority is like Athena without wisdom: impressive in name only. Authority means compliance can stop, modify, or escalate a transaction. It means policies are not optional when revenue is large enough. It means compliance concerns are documented, tracked, and resolved. It means the business must explain why it wants to proceed despite risk, not merely pressure compliance to “be practical.”

Practical compliance is not weak compliance. Practical compliance helps the business find a lawful and ethical path forward. But there is a difference between being practical and being domesticated. A good compliance function does not say no for sport. It says no when the facts, risks, and values of the company require it. It says, “not that way.” It says, “not with that intermediary.” It says, “not without diligence.” It says, “not until we understand the data, the customer, the payment, the conflict, or the control failure.”

The ECCP specifically asks how a company has responded when compliance raised concerns and whether transactions or deals have been stopped, modified, or further scrutinized because of compliance concerns. That is the right question. The ECCP states at one point, “Have they persisted in that commitment in the face of competing interests or business objectives?” Not whether compliance attended the meeting. Whether compliance changed the outcome. The ECCP further asked, “What role has compliance played in the company’s strategic and operational decisions? How has the company responded to specific instances where compliance raised concerns? Have some transactions or deals been stopped, modified, or further scrutinized as a result of compliance concerns?”

Resources Are a Statement of Values

Companies reveal what they value through budget. A board can praise compliance all day long. Still, if the function lacks staffing, technology, data access, training budget, investigative resources, and experienced personnel, the message is clear: “We support compliance, but preferably at a discount.”

No one would ask sales to grow revenue without systems, people, and market data. No one would ask finance to close the books with three spreadsheets, two interns, and a heroic attitude. Yet compliance teams are often expected to monitor global risk with underpowered tools and just enough headcount to keep the training completion dashboard from turning red.

That is not empowerment. That is wishful thinking. The ECCP asks whether compliance personnel have sufficient staffing to audit, document, analyze, and act on compliance efforts, whether resources are comparable to other parts of the company, and whether compliance has access to relevant data for timely monitoring and testing. Regarding funding and resources, the ECCP asks, “Has there been sufficient staffing for compliance personnel to effectively audit, document, analyze, and act on the results of the compliance efforts? Has the company allocated sufficient funds for the same? Have there been times when requests for resources by compliance and control functions have been denied, and if so, on what grounds? Does the company have a mechanism to measure the commercial value of investments in compliance and risk management?”

Those questions should make boards uncomfortable in a productive way. If the business has world-class tools to capture opportunity but outdated tools to detect risk, that imbalance is itself a governance decision.

Escalation: The Road from Concern to Action

Athena’s guidance matters because it reaches Odysseus when action is still possible. That is also the purpose of escalation. A well-designed escalation process moves concerns to the right people at the right time with enough information to make a decision. A weak escalation process traps concerns in email chains, local management reviews, or “let’s monitor this” limbo until the problem becomes a reportable event, a whistleblower complaint, or a headline.

Escalation should not depend on personality. It should not depend on whether the compliance officer is unusually persistent, politically skilled, or willing to become unpopular before breakfast. It should be built into governance.

What must be escalated? To whom? Within what timeframe? With what documentation? What happens when business and compliance disagree? Who decides? How are unresolved concerns reported to senior leadership or the board? These are not theoretical questions. They are the mechanics of wise counsel. Because without escalation, Athena is whispering in a locked room.

The Board’s Role: Ask Better Questions

Boards do not need to manage the compliance program day to day. That is not their role. But boards do need to oversee whether the program is real. That means asking better questions. The board should also pay attention to the moments when compliance loses. If compliance raised concerns and the business proceeded anyway, what happened? Was the decision documented? Were compensating controls added? Was the board informed? Did the risk later materialize? You learn a great deal about culture by examining what happens when wise counsel is inconvenient.

The Compliance Takeaway

Athena does not represent bureaucracy. She represents judgment. That distinction matters. Compliance officers are sometimes caricatured as the people who slow things down, complicate decisions, or drain the romance out of heroic commercial ambition. But the best compliance functions do something far more important: they help the organization see clearly before it acts.

They bring risk into the room. They challenge assumptions. They protect the company from cleverness without discipline. They help leaders understand that winning the deal, entering the market, launching the product, or pleasing the customer is not success if the path taken damages the company’s integrity.

Independent oversight is not ceremonial access. It is authority, resources, escalation, data, board engagement, and the organizational courage to let compliance challenge power. Odysseus needed Athena because brilliance has blind spots. So does every company.

The question is whether your Athena is truly in the boardroom or merely listed on the org chart.

Join us Tomorrow

Athena teaches that independent oversight is not ceremonial access but real authority, resources, escalation, data, board engagement, and the courage to let compliance challenge power. But that lesson only matters if the organization is willing to apply it to its most celebrated leaders, not merely its easiest targets. That brings us to Odysseus: the brilliant, strategic, results-driven leader every board wants and the very leader who can become the company’s most dangerous compliance risk when success becomes a shield. If Athena is the voice saying, “That may win the deal, but it may also wreck the kingdom,” Odysseus is the leader who wins the deal and forces the organization to ask whether anyone had the authority, courage, and independence to challenge how he did it. I hope you will join us tomorrow.

Categories
Sunday Book Review

Sunday Book Review: August 30, 2026, The New Books on Innovation Edition

In the Sunday Book Review, Tom Fox considers books that would interest compliance professionals, business executives, or anyone curious about the subject. It could be books about business, compliance, history, leadership, current events, or any other topic that might interest Tom. In this episode, we look at 4 new books on innovation.

  1. Off the Scales by Aimee Donnellan
  2. The UPS Man by Marc Levinson
  3. The Infinity Machine by Sebastian Mallaby
  4. Project Maven by Katrina Manson

Resources:

Our list today comes from the FT and Standard Chartered Business Book of the Year Award 2026 — the longlist

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From the Editor's Desk

From the Editor’s Desk: Aaron Nicodemus on the August and September in Compliance Week

In this episode of ‘From the Editor’s Desk,’ Tom Fox visits with Compliance Week editor-in-chief Aaron Nicodemus to discuss highlights from Compliance Week in August, take a look at what is coming down the pike in September in Compliance Week, and discuss the upcoming Third Party Risk Management and Supply Chain Summit in Chicago.

Tom and Aaron review key August coverage and upcoming priorities. They discuss new columnist Ben Mason’s “The Hidden Cost of Compliance Leadership,” outlining five recurring burdens for compliance leaders: independence that is often only theoretical, job risk from doing the role properly (including survey findings that nearly 70% of compliance officers have experienced retaliation), inability to voice doubts internally, the invisibility of effective prevention work, and weak leadership support—creating isolation and prompting ideas for safe forums such as the vetted CW app and event roundtables. Nicodemus highlights his Mayo Clinic whistleblower story alleging AI use may endanger patient privacy and outpace internal guardrails. He also describes a National Conference “Practitioner’s Briefing” distilling six Chatham House themes, previews a September 1MDB case study on enablers, plans AI-governance essays for National Compliance Officers Day, and promotes the Oct. 28–29 Chicago TPRM Summit.

Resources:

Aaron Nicodemus on LinkedIn

Compliance Week

Third Party Risk Management and Supply Chain Summit

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AI in Healthcare

AI in Healthcare: Five Healthcare AI Stories You Need to Know This Week – August 28, 2026

Welcome to AI in Healthcare in 5 Stories. This podcast is a weekly briefing on the five most important AI developments shaping healthcare, medicine, and life sciences. Each week, Tom Fox breaks down the latest stories on clinical innovation, regulation, privacy, compliance, patient safety, and operational transformation through a practical, business-focused lens. Designed for healthcare compliance professionals, executives, legal teams, clinicians, and industry leaders, the podcast moves beyond headlines to explain what each development means in the real world.

The top five stories for the week ending August 28, 2026, include:

  1. AI ROI in healthcare. (Becker’s Payer Issues)
  2. Using AI to detect heart disease from mammograms. (The Guardian)
  3. AI proving value in healthcare. (Healthcare IT News)
  4. Pharma’s next AI problem is authority. (PharmTech)
  5. Rural hospitals and AI investments. (Healthcare IT News)

For more information on the use of AI in Compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on Amazon.com.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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AI Today in 5

AI Today in 5: August 28, 2026, The Just Table Stakes Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. Bill Gates warns on AI. (NYT)
  2. AI governance beyond compliance. (IAPP)
  3. CIGNA AI chief on investing in AI. (Fortune)
  4. AI is now a table stake for compliance monitoring. (National Law Review)
  5. Will Agentic AI refine banking? (International Banker)

For more information on using AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on ⁠Amazon.com⁠.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠.

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Compliance and AI

Compliance and AI: Governance First: How Enterprises Deploy Agentic AI Safely with Nikunj Bajaj

What is the intersection of AI and compliance? What about machine learning? Are you using ChatGPT? These questions are just three of the many we will explore in this cutting-edge podcast series, Compliance and AI, hosted by Tom Fox, the award-winning Voice of Compliance. In this episode, host Tom visits with Nikunj Bajaj, Co-founder & CEO at TrueFoundry, to discuss enterprise agentic AI infrastructure, governance, and hidden costs.

Nikunj Bajaj brings a practical enterprise lens to the rise of agentic AI, shaped by years of working at the intersection of model development and production infrastructure. He argues that enterprise AI is not just a technical challenge but also an organizational one, because federated teams adopting different tools can quickly create sprawl, inconsistent controls, and governance gaps. To address this, he advocates for a unified gateway layer that centralizes observability and control while still allowing teams to build with best-of-breed frameworks, paired with targeted safeguards like auditability, RBAC, guardrails, and the ability to inspect or revert agent actions. Bajaj also stresses that successful enterprise adoption requires disciplined cost management through FinOps, chargebacks, and budget guardrails so companies can move quickly toward ROI without letting agentic systems become a governance risk or a runaway expense.

Resources:

Connect with Nikunj Bajaj

Learn More About TrueFoundry

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Daily Compliance News

Daily Compliance News: August 28, 2026, The Bill Gates Warns on AI 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:

  • Ex-Corsa Coal exec files appellate brief. (Law360)
  • California AG goes after Paramount. (WSJ)
  • Bill Gates warns on AI. (NYT)
  • More trouble for Malaysia ex-PM. (SCMP)

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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AI in Financial Services in 5 Stories

AI in Financial Services in 5 Stories – Week Ending August 28, 2026

Welcome to AI in Financial Services in 5 Stories. A practical weekly roundup of the five most important AI developments affecting banking, insurance, payments, asset management, and fintech. Each Friday, Tom Fox will break down the top stories that matter most through the lenses of compliance, risk management, governance, and business strategy. Designed for compliance professionals, executives, legal teams, and financial services leaders, it goes beyond headlines to explain why each development matters in a highly regulated industry. The result is a concise weekly briefing that helps listeners stay current on AI innovation while asking sharper questions about oversight, accountability, and trust.

This week’s stories include the following:

  1. Will Agentic AI refine banking? (International Banker)
  2. How customers use AI banking apps. (Yahoo!Finance)
  3. The huge danger in letting AI replace bankers. (CNBC)
  4. Is the future of audit real-time? (CFO Dive)
  5. Making AI decisions defensible. (Forbes)

For more information on the use of AI in Compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on Amazon.com.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.