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Compliance and AI

Compliance and AI: Steph Holmes on the Intersection of AI and Compliance

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. Today, Tom looks at the current Intersection of AI and Compliance with Steph Holmes, a long-time friend and Director, Ethics and Compliance Strategy at the EQS Group.

They discuss the evolving role of AI in corporate compliance, emphasizing its key role in modernizing compliance programs. Steph elaborates on the importance of evidence-based assessments of AI capabilities, the impact of AI on operational efficiency, and the need for human oversight in AI processes. She highlights EQS’s comprehensive AI performance test, which evaluated various AI models against multiple compliance tasks. The discussion also covers practical steps for compliance professionals to begin their AI adoption journey, as well as the necessity of continuous monitoring and risk-based evaluation to ensure effective AI deployment.

Key highlights:

  • Steph Holmes’ Role at EQS Group
  • AI in Compliance: Current Landscape
  • AI Performance Test Report
  • The Messy Middle of Compliance and AI
  • Human Oversight in AI Implementation

Resources:

Steph Holmes on LinkedIn

EQS Group LinkedIn

Where in the Loop: Corporate Compliance Insights

EQS Website

EQS Benchmark Report: AI Performance in Compliance & Ethics

Tom Fox

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Blog

Ethical AI Is Built in Procurement, Not Posters

In the ongoing conversation about AI, companies are increasingly highlighting their ethical principles. They publish responsible AI statements, share aspirational values, and post impressive slide decks. However, any experienced compliance professional knows that ethics does not live in posters. It lives in systems. It lives in contracts. It lives in the infrastructure choices that decide who holds power, who can be audited, and who is accountable when things go wrong.

When you pull back the curtain on most modern AI deployments, you find a hard truth. Ethical outcomes depend less on high-level values and more on the mundane details of compute access, data governance, vendor resilience, and transparency. Those details are not glamorous, but they are decisive. They are also exactly where the compliance function must lead. The companies that treat AI as a technical problem will struggle. The companies that understand AI as a governance problem will succeed. Compliance should be at the center of that governance effort.

The Infrastructure Beneath Ethical AI

The most important element of ethical AI is the part no one sees. The infrastructure decisions made today are the ethical outcomes of tomorrow. Consider four core factors that determine the integrity of an AI system long before it begins making predictions.

a. Compute Access

The amount of compute you grant, the regions in which it can be used, and the failover plan for outages are not IT decisions. They are about fairness, safety, and continuity. If only certain business units have access to the most powerful models, you have created inequities inside your own walls. If you cannot maintain operations during a provider outage, you have made a resilience gap that regulators will notice.

b. Data Governance

AI systems amplify the quality and cleanliness of your data practices. Data lineage, retention schedules, classification levels, and access controls determine who can see what, when, and under what safeguards. If the data is flawed, every model output built on it is flawed. Compliance already governs data privacy, confidentiality, and use restrictions. AI raises the stakes.

c. Vendor Resilience

The more an organization invests in a single AI provider, the more dependent it becomes on that provider’s risk posture. Multi-cloud strategies, vendor exit rights, and enforceable SLAs are not operational niceties. They are governance tools to prevent concentration risk. Compliance has long experience managing third-party risk; AI vendors are simply the newest category.

d. Model Operations

Model versioning, approval workflows, rollback procedures, and audit trails determine how quickly an organization can detect harm and correct it. These operational controls map almost perfectly onto compliance best practices. They reflect the same principles that underpin any effective risk management program: evidence, traceability, and documented decision-making.

Where Compliance Must Lead

Most organizations underestimate the extent to which AI governance requires the same discipline found in mature compliance programs. The compliance function knows how to operationalize policies, create audit trails, and embed accountability. These strengths translate directly into AI. Below are the areas where compliance should play the lead role.

1. Embedding Ethical Standards Into Procurement

Ethical AI begins with ethical procurement. RFPs should require model documentation, bias testing, data ownership guarantees, audit logs, content filtering, and evidence of secure development practices. A vendor that cannot demonstrate its internal controls will not protect your ethical commitments. Compliance is uniquely positioned to identify those red flags.

2. Contracting for Power, Not Promises

Every compliance professional knows that a vendor promise without contractual force is aspiration, not assurance. AI contracts must include termination for harm, financially meaningful remedies, data portability, and clear assignment of responsibilities. Regulators will expect companies to demonstrate that they negotiated governance into their agreements.

3. Designing for Resilience

AI systems break in unfamiliar and sometimes spectacular ways. Multi-region deployment, validated failover paths, and regular stress testing are mandatory. Resilience is an ethical value because it protects customers, employees, and stakeholders from foreseeable harm. Compliance should insist on documented resilience planning as part of deployment approval.

4. Governing the Data Layer

Data minimization, differential access, immutable lineage, and standard retention schedules must be embedded across AI use cases. AI does not excuse a company from its privacy or data-governance obligations. It heightens them. Compliance should ensure that every AI initiative begins with a data governance review before a single line of code is written.

5. Operationalizing Oversight

AI oversight is not a once-a-year assessment. It is a living discipline. Compliance should push for model risk reviews, red-team exercises, change-control approvals, and clearly defined escalation pathways. When issues arise, there must be a time-boxed rollback plan in place. Clearly assigned control owners must be accountable for results.

6. Measuring What Matters

Without metrics, oversight is performance art. Companies should measure false positives and false negatives for each AI use case, especially across protected classes. They should track incident rates, drift detection outcomes, model approval times, and vendor SLA performance. These indicators form a dashboard that demonstrates whether AI governance is real or merely decorative.

7. Funding Ethics as an Operational Requirement

Ethical AI is not free. It requires a budget for monitoring, red teaming, data curation, and external verification. Compliance should push for these resources and make the case that ethics is a form of operational continuity. A company that cannot demonstrate that it has funded its governance model will struggle in any regulatory examination.

8. Building Exit Capability

Most companies underestimate how difficult it is to transition away from an AI vendor. Compliance should require that every material AI system have an exit plan that includes timelines, data-migration standards, and a documented process to ensure continuity. Only an exit tested under realistic conditions qualifies as a real control.

9. Clarifying Accountability

AI governance fails when accountability is diffuse. Every operational risk must have an owner. Compliance should map each AI risk to a responsible executive and require quarterly reviews. Regulators do not want to know who wrote the policy. They want to know who owns the risk.

10. Training the Front Line

AI governance is not the exclusive domain of data scientists. Product teams, procurement staff, and engineers must understand their responsibilities. Compliance should provide scenario-based training and reward early escalation. Culture determines how quickly issues surface, and AI issues must surface fast.

Closing Thoughts

Ethical AI is not an aspirational project. It is a systems problem, a contracting problem, a data problem, and an accountability problem. Compliance has the experience and discipline to lead the organization through these challenges. When procurement, contracts, and architecture embody the company’s values, ethical outcomes follow. When they do not, no principle statement on a website will save you.

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ACI FCPA Conference 2025

ACI-FCPA Conference Speaker Preview Series – Laura Perkins on Compliance as a Team Sport

In this episode of the ACI-FCPA and Global Anti-Corruption Conference Speaker Podcasts series, Laura Perkins discusses her workshop at the event, “Compliance as a Team Sport: A Comprehensive Guide to Building Smarter, Integrated, and Cross-Functional Compliance Programs.”

Some of the issues the panel will discuss are:

  • Integrating Compliance Functions;
  • Building a cross-functional compliance team;
  • Breaking down siloes.

I hope you can join me at the ACI–FCPA Conference. This year’s event will take place on December 3-4 at the Gaylord National Resort & Convention Center in National Harbor, Maryland, near Washington, D.C. The lineup of this year’s event is simply first-rate, featuring some of the top FCPA professionals, white-collar attorneys, and compliance practitioners in the field.

The 2025 program is being completely redesigned to help your organization stay agile, responsive, and ahead of the curve. Expect a dynamic agenda shaped by real-world priorities, practical takeaways, and the most cutting-edge thinking in compliance—led by a faculty of global practitioners with boots on the ground, encountering the very risks that come across your desk.

Please join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount by using the code D10-999-CPN26.

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Blog

When Maps Become Moral Documents: Why Compliance Must Own the Lines That Shape Risk

In compliance, we spend a great deal of time talking about frameworks, policies, and procedures. Yet some of the most powerful instruments in any governance ecosystem do not look like policies at all. They look like maps. They look like heat grids, risk matrices, shaded zones, and tidy borders that suggest precision even when uncertainty runs underneath them like an underground river.

From FEMA flood panels to enterprise risk heat maps, every organization uses maps to tell itself where danger lies and where safety supposedly begins. But here is the hard truth: maps are not technical artifacts. Maps are moral documents. They allocate duties, distribute the burden, and tell people whether they need to prepare or can relax. They shape budgets, attention, and ultimately accountability. And if the compliance function is not involved in how those maps are created, interpreted, and refreshed, then the organization is making ethical choices without a moral lens.

Today, I want to explore why maps are moral, what that means for governance, and what the compliance professional must do to ensure these documents reflect not only data but also duty.

Maps Allocate Duty

Every map draws lines that determine who must act. A FEMA flood map decides whether a camp, neighborhood, or business must carry flood insurance. A corporate risk heat map determines which business units receive enhanced oversight and which do not. A supply chain risk atlas determines who must perform due diligence and who can move goods without interruption.

Once a line is drawn, responsibility flows from it. A zone marked “high risk” sets expectations for controls, investment, and scrutiny. A zone marked “low risk” effectively signals that no further action is required. These judgments may feel technical, but they are deeply moral. They define the boundaries of duty. Compliance must be at the table when those lines are drawn. Otherwise, risk decisions become engineering exercises that inadvertently shift ethical burdens onto people who did not choose them.

Maps Encode Assumptions

Maps are built on models, thresholds, and historical patterns. But assumptions sit inside those models like coiled springs.

Which data is used?

Which data is excluded?

Which thresholds define severity?

Which events are treated as plausible?

Which sources are considered authoritative?

A map is never neutral. It always privileges certain histories, geographies, and scenarios over others. A corporate misconduct heat map based solely on historical hotline data will inevitably underweight emerging risks. A supply chain map that excludes subcontractors misses where real harm often occurs. A financial crime exposure map that relies solely on official lists will miss high-risk jurisdictions operating in gray zones. When compliance reviews these maps, the question is not whether the data is accurate. The question is whether the assumptions align with the organization’s ethical obligations.

Maps Shape Budgets and Behavior

Color drives capital. If an enterprise risk map identifies three red zones and ten green zones, everyone knows where the money is going. Green becomes the land of the unexamined. Yellow becomes “monitor and report.” Red becomes “fix this yesterday.” The danger arises when risk colors are treated as immutable truth rather than directional guidance. Compliance professionals know that a green box is not safety; it is an artifact of a model. And sometimes, it is an artifact of politics.

When business units understand that the map determines their workload, incentives emerge to influence the color. This is precisely why compliance must defend the integrity of the map and maintain independence in how risks are classified. The ethics are simple: if a map drives budget decisions, then the standards behind it must be transparent, fair, and aligned with the organization’s core mission.

Maps Create Winners and Losers

Every risk map is also a distributional map. Departments inside a red zone receive controls, resources, and escalation routes. Departments outside it may receive none. That inequity can have real consequences. Red zones experience heavy scrutiny but also benefit from board-level attention. Green zones may be left alone, but they also lack the resources needed when a new risk emerges.

Flood maps create similar inequities: one parcel receives insurance, mitigation funds, and federal guidance; the parcel across the street gets nothing until the water rises high enough to erase the line. Compliance must examine whether the “winners” and “losers” created by risk maps reflect risk reality or merely historical artifacts.

Maps Fix Narratives

Once published, maps become the truth. Boards rely on them. Auditors embed them into work plans. Regulators ask about them. Data teams update them. And leaders cite them to explain why certain risks were or were not prioritized. A flawed map can harden into institutional fact. It can shape decision-making for years. It can justify inaction. It can mask brewing crises. And when risk crystallizes into harm, those relying on the map will discover too late that precision was an illusion. Compliance serves as the conscience that returns the organization to humility. Every map should come with a disclaimer: “Here is our best understanding as of today, but all maps are drafts.”

Governance Checklist for Ethical Mapping

Compliance can bring discipline and transparency by treating maps like policies. They require version control, authorship, documented assumptions, and scheduled refresh cycles. Here is a governance lens for any map that influences risk:

  1. Provenance
  2. Who created the map, with what data, and what was deliberately excluded? If exclusion changes the ethical calculus, it must be surfaced.
  3. Alignment to Risk Appetite
  4. Are thresholds tied to enterprise risk appetite, the ECCP, and regulatory expectations? Or did the model make them convenient?
  5. Equity Across Stakeholders
  6. Who bears the residual risk outside the lines? What does the map fail to capture about vulnerable populations, small sites, or contractors?
  7. Scenario Overlays
  8. Have low-probability, high-impact events been tested against the map? Compliance should insist on stress testing.
  9. Update Cadence
  10. Does the map have an expiration date? Every risk map should.
  11. Auditability
  12. Can the map be reconstructed from its inputs and assumptions? If not, it is a narrative, not a control.
  13. Communication Duty
  14. Every map must include plain-language guidance, escalation paths, and explicit caveats for those adjacent to but outside the risk zones.
  15. Budget Connection
  16. Colors must correspond to predetermined actions. Otherwise, resource allocation becomes politics by palette.

What Compliance Must Do

Compliance does not need to own the model. Compliance must own the ethical underpinnings of the model. That means three responsibilities:

  • Own the legend.
  • The color definitions, thresholds, and assumptions must reflect ethical and legal duties, not convenience.
  • Bring the board a map-ethics memo.
  • One page: assumptions, blind spots, intended uses, and the refresh cadence.
  • Ground-truth everything.
  • Walk the sites, review complaints, and test whether green zones reflect lived reality.

Maps guide action. Compliance ensures that the action they guide aligns with the organization’s values, obligations, and responsibilities to its stakeholders.

Conclusion

Maps are powerful. They shape perception, allocation, and accountability. But they are not neutral. They are moral documents and, therefore, compliance documents. When compliance embraces that role, maps become more than diagrams. They become tools for fairness, integrity, and informed oversight.

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AI Today in 5

AI Today in 5: November 20, 2025, The Gemini 3 Edition

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

  1. AI and real-world real estate compliance. (HousingWire)
  2. Replacing manual cyber compliance with AI. (JerusalemPost)
  3. Gemini 3 was released. (Google)
  4. Will AI deepen inequality and hasten war? (NBC)
  5. AI and governance overhauling AML. (FinTechGlobal)

For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

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SBR - Authors' Podcast

SBR-Authors Podcast: Risk is the Soundtrack of Life with Jim Massey

Welcome to the SBR-Authors Podcast! In this podcast series, Host Tom Fox visits with authors in the compliance arena and beyond. In this episode, Tom Fox welcomes back Jim Massey to discuss Jim’s latest book, ‘Risk in Action: A Leader’s Guide to Clarity.’

They take a deep dive into how the book builds on the themes outlined in ‘Trust in Action,’ focusing on the comprehensive approach to managing risk, trust, and fear. Jim shares insights on redefining risk not as a binary choice but as a polarity to be managed, offering actionable steps for business and compliance leaders. He also introduces his new AI-driven risk assessment tool, designed to provide real-time, actionable insights. Jim emphasizes the importance of embracing risk as an opportunity for innovation and shares his key leadership lessons for navigating the ever-changing business landscape.

Key highlights:

  • The Genesis of ‘Risk in Action’
  • Understanding Risk and Its Importance
  • The Role of Fear in Risk Management
  • Innovative Risk Management Strategies
  • Leadership and Risk
  • The Future of Risk Assessments

Resources:

Risk in Action on Amazon

Jim Massey Website

Jim Massey on LinkedIn

Eastward.ai Website

Tom Fox

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Compliance Tip of the Day

Compliance Tip of the Day – Due Diligence

Welcome to “Compliance Tip of the Day,” the podcast that brings you daily insights and practical advice for 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 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.

This week, we are reviewing the third-party risk management process. Today, we focus on due diligence.

For more on this topic, check out The Compliance Handbook: A Guide to Operationalizing your Compliance Program, 6th edition, which LexisNexis recently released. It is available here.

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Daily Compliance News

Daily Compliance News: November 20, 2025, The End to Whistleblower Protection 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:

  • The Trump Administration is set to end whistleblower protection for federal employees. (Reuters)
  • Turning compliance into a competitive advantage. (CW)
  • The EU is looking to ease back on tech reg. (Bloomberg)
  • BDO to move from national to regional practice groups. (FT)

The Daily Compliance News has been honored as the No. 2 in the Best Regulatory Compliance Podcasts category.

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Daily Compliance News

Daily Compliance News: November 19, 2025, The Accountability 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:

  • Supply Chains are vulnerable to Chinese exploitation. (WSJ)
  • The fraud case against Adani is in limbo. (NYT)
  • French police raid Altice re: corruption allegations. (Bloomberg)
  • Hold tech companies accountable for fraud. (FT)

The Daily Compliance News has been honored as the No. 2 in the Best Regulatory Compliance Podcasts category.

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Compliance Into the Weeds

Compliance into the Weeds: Uncovering FCPA Violations: Millicom’s Complex Case Involving Drug Cartel Funds

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the intricate details of a recent FCPA enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala.

The discussion uncovers how Millicom’s joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ’s earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom’s operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions.

Key highlights:

  • Details of the FCPA Enforcement Action
  • Millicom’s Joint Venture in Guatemala
  • Self-Disclosure and DOJ’s Response
  • Timeline of Events and Corruption Details
  • Drug Trafficking and Bribery Connections
  • Implications and Compliance Lessons

Resources:

Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.