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Compliance Tip of the Day

Compliance Tip of the Day – NBA Betting Scandal-Introduction

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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 will mine the ongoing NBA betting scandal for compliance lessons. Today in Part 1, we introduce the scandal, those involved, and the questions we have at this point.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Daily Compliance News

Daily Compliance News: November 3, 2025, The World Athletics 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, including compliance, ethics, risk management, leadership, or general interest, relevant to the compliance professional.

Top stories include:

  • Financial fraud hits World Athletics. (BBC)
  • Best Career advice received. (BusinessInsider)
  • FirstEnergy execs getting preferential treatment? (cleveland.com)
  • JPMorgan flagged Epstein transactions as far back as 2002. (WSJ)

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

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FCPA Compliance Report

FCPA Compliance Report – Navigating the Complexities of Self-Disclosure Amidst Political and Legal Uncertainties

In this episode, Tom Fox welcomes back Hughes Hubbard partner Mike DeBernardis to explore the unprecedented criminal indictment of Smartmatic and its implications on self-disclosure policies under the current administration. They discuss the rare occurrence of a company facing criminal charges and how it complicates the risk assessment for potential self-disclosure. The conversation covers the unpredictable nature of DOJ actions, the impact of political influence, and the challenges this situation presents for legal advisors and their clients. They also explore the broader implications for corporate compliance, including the increased complexity in predicting outcomes and the necessity for thorough internal investigations.

Key highlights:

  • Discussion on Smartmatic Indictment
  • Challenges in Self-Disclosure
  • Political Influence and Risks
  • Client Conversations and Risk Assessment

Resources: 

Hughes Hubbard & Reed

Mike DeBernardis on LinkedIn

Tom Fox

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AI Today in 5

AI Today in 5: November 3, 2025, The AI Compliance Officer Edition

Welcome to AI Today in 5, the newest edition 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 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.

Top AI stories include:

  1. AI is making death threats more realistic. (NYT)
  2. Board oversight of AI has tripled since 2024. (CCI)
  3. AI predictions for 2026. (Philadelphia Business Journal)
  4. AI Compliance Officer as a managed service. (ISA Guide)
  5. China pushes the APAC region to counterbalance the US in AI. (Reuters)

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

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Blog

The NBA Betting Scandal, Part 4: The Role of Compliance in Sports Leagues

We previously considered the who, the what, and the histories of the NBA betting scandal. Today, we explore the ‘how’: how a compliance function could have prevented this, and what both sports leagues and corporations can learn from each other about safeguarding integrity. Whether your organization manages global investments or global fan bases, the lesson remains the same: governance without compliance is merely a façade, and compliance without culture is noise.

The NBA’s Blind Spot: Compliance Is Not Just for Corporations

The NBA, like many professional leagues, has long emphasized rules enforcement rather than risk management. It has compliance policies, anti-gambling rules, player education programs, and disclosure requirements, but these are largely reactive. What’s missing is the proactive, integrated approach that corporate compliance professionals have built over the last two decades.

Think about the Sarbanes-Oxley Act (SOX). Following a series of accounting scandals in the early 2000s, companies not only created new rules but also established compliance infrastructures, internal controls, whistleblower channels, independent oversight committees, and risk-based monitoring systems.

The NBA, in contrast, still operates under a “trust-the-player” model, one that assumes personal integrity will outpace financial temptation. The DOJ indictment proves that assumption no longer holds. In today’s data-driven, gambling-integrated sports environment, league compliance must evolve into a true governance function, not merely a disciplinary office.

The Corporate Compliance Framework Applied to Sports

To understand what that evolution might look like, I want to apply the classic corporate compliance framework — the Seven Elements of an Effective Compliance Program, as outlined in the US Sentencing Guidelines —to a professional sports context.

1. Standards and Procedures

Corporations have codes of conduct that define acceptable behavior. Sports leagues have them too, but they’re often vague or limited to rulebooks. The NBA needs a clear, enforceable code of compliance that articulates not just what players cannot do, but also why a framework rooted in integrity, rather than punishment, is necessary. Imagine a “Sports Compliance Charter” that explicitly defines insider betting as a form of fraud, akin to insider trading. That reframing alone would elevate the stakes, moving it from a “rules violation” to a “trust violation.”

2. Oversight and Accountability

Corporate boards delegate compliance oversight to audit and ethics committees. The NBA’s governance, however, largely resides in the Commissioner’s office. That’s too much concentration of oversight for a league managing billions in sports betting partnerships.

A modern model would involve an independent Compliance and Integrity Committee reporting directly to the league’s Board of Governors. This committee would review potential conflicts of interest, audit betting-related data, and monitor patterns of suspicious player performance. Independence breeds credibility.

3. Due Diligence and Risk Assessment

Before a merger, corporations perform risk-based due diligence. Before every season, leagues could conduct a similar compliance risk assessment, focusing on areas such as gambling exposure, data security, and player-agent relationships. Who are the players with large gambling debts? Which coaches or trainers have undisclosed financial interests in betting companies? These are not personal invasions; they are integrity controls. Compliance starts by identifying risk, not reacting to scandal.

4. Training and Communication

Corporate compliance officers understand that training isn’t about memorizing policy; it’s about shifting mindsets. The NBA’s anti-gambling training should move beyond the “don’t do this” model toward scenario-based ethics education where players explore gray areas, learn about real-world enforcement cases, and understand the long-term reputational damage of misconduct. In corporate terms, this distinction lies between check-the-box training and culture-building education. Compliance is not a slide deck; rather, it is a dialogue.

5. Monitoring and Auditing

Just as compliance programs utilize transaction monitoring or expense audits, the NBA can leverage data analytics to identify irregularities in player performance and betting patterns. If a player suddenly exits two games early, as Jontay Porter did, that should trigger an automatic integrity review, just as an anomalous financial transaction might trigger an AML alert.

This is where the corporate concept of continuous monitoring can revolutionize sports compliance. Algorithms already track betting odds in real-time; coupling that data with player analytics would enable early detection of suspicious trends.

6. Reporting and Whistleblowing

No compliance program functions without psychological safety. The NBA should establish anonymous channels for reporting concerns not only for employees but also for players, trainers, and referees. If a player suspects a teammate is manipulating outcomes, there must be a trusted way to report it without fear of retaliation. In the corporate world, such mechanisms are essential to uncovering misconduct early. The same must apply to locker rooms.

7. Enforcement and Remediation

Discipline must be consistent and transparent. When corporations investigate misconduct, they publish their findings, impose proportionate penalties, and integrate the lessons learned. The NBA’s enforcement process remains opaque, with outcomes often perceived as being influenced by politics. Public trust demands transparency in discipline. When penalties are seen as fair and consistent, they reinforce the league’s credibility, just as consistent FCPA enforcement enhances the integrity of the corporate sector.

Compliance Culture: The Missing Link

Ultimately, no framework works without culture. Compliance officers recognize that even the most sophisticated policies are ineffective if the culture prioritizes winning at any cost. Sports leagues often celebrate risk-taking, competitiveness, and personal brand-building, traits that, when unchecked, evolve into entitlement and moral flexibility. That’s the same cultural recipe that fueled Enron, Wells Fargo, and Volkswagen.

The solution is not to suppress ambition, but to align it with ethical purpose. Imagine if the NBA  and other leagues embedded compliance values into player leadership programs, performance reviews, and even contract bonuses. The message would shift from “Don’t get caught” to “Play with integrity.”

The Compliance Officer as Integrity Architect

For compliance professionals, this scandal presents an opportunity to reimagine the role of the compliance officer not just in business, but in every trust-based institution. In corporations, the CCO acts as an integrity architect, designing systems that enable ethical decision-making even under pressure. Sports leagues need the same role. Call it the Chief Integrity Officer: a function that bridges governance, analytics, education, and enforcement.

This role could oversee not just gambling risks, but conflicts of interest, sponsorship ethics, and social media conduct, the entire ecosystem of reputation management. In the modern economy, integrity is a managed asset, and someone must be accountable for its stewardship.

Moreover, corporate compliance programs succeed when leadership models ethical behavior. The same applies in sports. When coaches or executives participate in insider schemes, as alleged in the case of Damon Jones, they set a destructive tone. But imagine the opposite, a league where coaches discuss integrity as openly as game strategy, and general managers reward transparency over secrecy. Tone at the top is contagious. In corporations, it builds trust. In sports, it rebuilds it.

From Scandal to Systemic Change

The NBA betting scandal is a compliance failure, but it can also be a catalyst. Like Enron and WorldCom before it, this crisis can drive reform if the league commits to systemic change.

For compliance officers, the takeaway is both familiar and urgent:

  • Do not wait for regulation to force change.
  • Design compliance as governance, not guidance.
  • Measure culture as closely as you measure performance.

Whether you’re managing a multinational enterprise or a billion-dollar sports league, the principle remains constant: integrity isn’t enforced; it’s engineered.

Final Thought: Compliance Beyond the Court

The NBA’s scandal is not simply a sports story. It is a warning about what happens when performance eclipses principle. For compliance professionals, it also serves as a form of validation.

Our work, often behind the scenes, is what protects institutions from self-destruction. The NBA didn’t fail because of bad luck; it failed because of missing systems. The same can happen in any organization that mistakes compliance for bureaucracy instead of recognizing it for what it truly is: the infrastructure of trust. Whether you are in a boardroom or a locker room, culture always calls the next play.

Join us tomorrow, as we continue our exploration in Part 5, to delve into the intersection of culture, incentives, and the psychology of ethical failure. We will examine how even well-meaning individuals cross ethical lines when the system prioritizes results over values.

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Sunday Book Review

Sunday Book Review: November 2, 2025, The Tackling Climate Change Edition

In the Sunday Book Review, Tom Fox considers books that would interest compliance professionals, business executives, or anyone with a curiosity. It could be books about business, compliance, history, leadership, current events, or any other topic that might interest Tom.  Today, we review four top books on tackling climate change.

  • Cleaning the Air by Hannah Ritchie
  • Rooted in Change by Jane Masters and Andrew Neather
  • The New Global Possible by Ani Dasgupta
  • The Growth Story of the 21st Century by Nicholas Stern

Resources:

Four hopeful guides to tackling climate change in the FT.

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending, November 1, 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 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.

Top weekly stories include:

  • Boeing hit with $5bn in late fee penalties. (BBC)
  • Corruption probe at Historic Environment Scotland. (BBC)
  • KPMG, Novo Bank targeted in corruption probe. (Bloomberg)
  • Ukraine receives an award for ABC. (Ukrinform)
  • All about FATF. (Bloomberg)
  • Texting in meetings is a CEO no-no. (WSJ)
  • Will Tesla lose Musk (w/o $1tn pay package)? (Yahoo!Finance)
  • Does insider trading = insider betting? (Bloomberg)
  • Tom Hayes sues UBS for $400MM. (Reuters)
  • How will the US define ‘country of origin’? (NYT)

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

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You can purchase a copy of my new book, Upping Your Game, on Amazon.com

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From the Editor's Desk

From the Editor’s Desk: Compliance Week’s Insights and Reflections for October and into November 2025

In this episode of ‘From The Editor’s Desk’ podcast, hosts Tom Fox and Aaron Nicodemus delve into key compliance issues featured in Compliance Week. Tom and Aaron discuss the top stories from Compliance Week in October, look at some stories that will appear in November, and provide a preview of upcoming content and events.

They discuss the insights from a case study on Lafarge’s anti-bribery issues linked to cartels and terrorist organizations, as well as challenges in business due diligence in high-risk areas. The episode also covers recent trends around DOJ compliance monitorship under different administrations, insights into Foreign Corrupt Practices Act (FCPA) enforcement, and evolving compliance issues related to artificial intelligence (AI). Finally, they highlight upcoming Compliance Week initiatives and webinars, focusing on career pathways in compliance, the importance of due diligence in high-risk environments, and the practical applications of AI in the compliance field.

Resources:

Aaron Nicodemus on LinkedIn

Compliance Week

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Popcorn and Compliance

Popcorn and Compliance: Episode 5 – Invisible Compliance: Lessons from The Invisible Man

Welcome to a special series of Popcorn and Compliance. In this series, we will examine the Classic Universal Monster Movies from the 1930s and 1940s, mining them for compliance lessons. (Yes, it really is an excuse to rewatch them all.) In this series, we will examine Frankenstein, Dracula, The Wolf Man, The Mummy, and conclude with The Invisible Man. In today’s episode of ‘Popcorn and Compliance,’ we wrap up our series by analyzing the 1933 classic, ‘The Invisible Man,’ for compliance insights.

Joined by Fiona and Timothy, Fox explores how Claude Rains’ portrayal of Jack Griffin, a scientist who becomes unhinged after discovering invisibility, parallels challenges in corporate compliance. The episode distills five key lessons: the perils of lacking transparency, the necessity of accountability, the critical role of organizational culture, the exponential risks when innovation outpaces ethics, and the importance of crisis preparedness. This episode highlights the importance of making the invisible visible in compliance practices, aiming to uncover hidden risks, enforce accountability, and maintain robust ethical standards.

Key highlights:

  • Exploring ‘The Invisible Man’
  • Lesson 1: The Dangers of Lack of Transparency
  • Lesson 2: The Importance of Accountability
  • Lesson 3: The Role of Culture in Compliance
  • Lesson 4: Innovation and Ethical Boundaries
  • Lesson 5: Crisis Preparedness
  • Final Thoughts

Resources:

Compliance Lessons from the Invisible Man on the FCPA Compliance and Ethics Blog

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Data Driven Compliance

Data Driven Compliance – Navigating the Failure to Prevent Fraud: Key Insights and Implications

Welcome to Season 2 of the award-winning Data Driven Compliance. In this new season, we will examine the new Failure to Prevent Fraud offense. Join host Tom Fox as we explore this new law and how to comply with it through the lens of data-driven compliance. This podcast is sponsored by konaAI. In this concluding episode of Season 2, Tom Fox is joined by Steptoe LLP partners Zoe Osborne, Judy Krieg, and Matt Galvin for an in-depth discussion on the UK’s new fraud prevention offense.

The panel explores the jurisdictional reach of the law, highlighting the broad scope that can impact U.S. companies, even those with limited ties to the UK. They delve into the roles of potential enforcers such as the Serious Fraud Office, the Crown Prosecution Service, and the Financial Conduct Authority. Practical advice is shared on leveraging AI for compliance, maintaining robust fraud prevention measures, and documenting decision-making processes to ensure transparency and accountability. This episode provides comprehensive insights essential for corporate compliance professionals navigating these complex regulatory landscapes.

Key highlights:

  • Overview of Failure to Prevent Fraud Offense
  • Enforcement Agencies and Their Roles
  • Technological Solutions for Fraud Prevention
  • UK DPA Process and Jurisdictional Issues

Resources:

Steptoe LLP

Matt Galvin

Zoe Osborne

Judy Krieg

Click here for konaAI White Paper Rethinking Compliance: Practical Steps for Adapting to the UK’s New Fraud Legislation

Connect with Tom Fox on LinkedIn