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Michigan Man, Part 2 – Individual Accountability: Compliance and Ethics Violations at the Center of the Crisis

Part 1 of this series established that the Sherrone Moore story is both a human tragedy and an institutional crisis. In Part 2, we turn to a more difficult but necessary task. Compliance professionals must ask a direct question: What did Moore do that violated compliance and ethics expectations, and why do those actions matter beyond college football?

The answer is uncomfortable because it involves more than a single lapse in judgment. The facts as currently known describe a pattern of conduct that strikes at the heart of any credible compliance program: dishonesty during investigations, misuse of power, disregard for institutional policy, and an apparent belief that personal status insulated him from consequences.

Compliance Is About Truth-Telling

At the core of every compliance program is a simple, non-negotiable principle: tell the truth when the organization asks questions. That principle applies whether the inquiry involves financial controls, harassment allegations, or NCAA violations. Once an individual lies during an investigation, the issue ceases to be a narrow policy breach and becomes an integrity failure. As a friend of mine told me once, “As one of my partners said when a managing partner was having an affair, ‘if he’ll do that to his wife, imagine what he’ll do to his partners.’” Sherrone Moore crossed this line well before his dismissal as head coach.

During the Connor Stalions sign-stealing investigation, Moore deleted text messages exchanged with Stalions and later provided what the NCAA described as an implausible explanation for doing so. That conduct resulted in NCAA suspensions and remains part of the formal record of compliance violations tied to Moore personally. ESPN

From a compliance perspective, this matters far more than sign stealing itself. Deleting records during an investigation undermines document retention obligations, impedes fact-finding, and signals a willingness to prioritize personal or programmatic interests over institutional integrity. In the corporate world, the parallel would be deleting emails during a regulatory inquiry. No compliance officer would treat that as a minor infraction.

Repeated Dishonesty During Investigations

The more recent investigation into Moore’s relationship with a female staffer raises even more serious concerns. According to reporting, the University of Michigan launched an inquiry after receiving an anonymous tip alleging an inappropriate relationship. Both Moore and the staffer denied any ties, and the investigation initially stalled for lack of corroborating evidence. ESPN

That denial later proved false when the staffer disclosed corroborating evidence confirming a multi-year intimate relationship. At that moment, the issue shifted decisively from a policy violation to an ethics failure.

From a compliance standpoint, the problem is not merely the relationship itself. It is the active misrepresentation to investigators, i.e., intent. Lying to internal or external investigators destroys trust in the investigative process and forces organizations to rely on incomplete or inaccurate information when making risk decisions. It also exposes the institution to claims that it ignored or mishandled misconduct, even when the real issue was a senior leader’s deception.

Abuse of Power and Conflicts of Interest

Most university and corporate codes of conduct prohibit intimate relationships between supervisors and subordinates or require disclosure and mitigation when they do. These rules are not moral judgments. They are risk controls designed to prevent coercion, favoritism, retaliation, and exploitation.

Moore’s alleged multi-year relationship with a staffer squarely implicates these risks. As head coach and, previously, as an assistant coach, Moore held a position of significant authority within the athletic department. Even if the relationship was initially consensual, the power imbalance is unavoidable. Compliance professionals recognize that consent in such circumstances is inherently complicated and that organizations bear responsibility for preventing these situations from arising.

Failure to disclose the relationship deprived the university of the opportunity to implement safeguards, reassign reporting lines, or otherwise manage the conflict. That omission constitutes a clear ethics violation independent of any later criminal allegations.

Escalation Beyond Policy Violations

The most disturbing allegations arise from events following Moore’s termination. Prosecutors allege that after the relationship ended and Moore was fired, he went to the staffer’s residence without permission, engaged in repeated unwanted communications, and threatened self-harm while inside her home. NYT

While the criminal justice system will determine legal responsibility, compliance professionals must recognize how quickly misconduct can escalate when earlier controls fail. What began as an undisclosed relationship allegedly progressed into stalking behavior and an incident that law enforcement deemed serious enough to warrant felony charges.

This escalation underscores a core compliance truth: that early intervention matters. When organizations fail to address misconduct promptly and transparently, risks compound. Personal crises become workplace crises. Workplace crises become institutional crises.

Retaliation and Intimidation Risks

Another compliance dimension cannot be ignored. Prosecutors allege that Moore made statements to the staffer suggesting that she had “ruined his life” and that his blood would be “on her hands. From a compliance lens, such statements raise red flags around intimidation and retaliation. NYT

Whistleblower and reporting systems depend on employees feeling safe to come forward. Any conduct that could reasonably be perceived as threatening or coercive undermines that system. Whether intentional or not, such behavior chills reporting and exposes organizations to significant liability.

The Myth of the Star Performer Exception

One of the most consistent themes in compliance failures across industries is the star performer exception. High performers convince themselves, and sometimes their organizations, that rules are flexible when success is at stake. Moore’s trajectory fits this pattern uncomfortably well.

Despite prior compliance issues, including NCAA suspensions, Moore was elevated to head coach of one of college football’s most prominent programs. Each unresolved issue reinforced the perception that consequences were manageable and survivable. That perception is toxic to any ethical culture. Compliance professionals know that prior misconduct is one of the strongest predictors of future misconduct. Moore’s history should have triggered heightened scrutiny, not diminished concern.

Why Individual Accountability Matters

It is tempting to view Moore as a tragic figure overtaken by personal failure. That view is human and compassionate, but it cannot obscure the reality of compliance. Moore made choices. He chose to delete records. He decided to misrepresent facts to investigators. He chose not to disclose a prohibited relationship. He allegedly took actions that led to criminal charges.

Individual accountability is essential because without it, compliance programs lose credibility. Employees notice when leaders are treated differently. Regulators notice when organizations minimize misconduct by senior figures. Over time, the erosion of accountability becomes cultural.

Compliance Takeaways

For compliance professionals, the Moore case reinforces several hard truths:

  • Dishonesty during investigations is a red-line violation.
  • Conflicts of interest must be disclosed and managed, not hidden.
  • Power imbalances amplify ethical risk.
  • Past misconduct predicts future risk.
  • Star performers do not deserve special rules.

In Part 3 of this series, I will turn from individual accountability to institutional failure. The University of Michigan did not create Moore’s choices, but it did create the environment in which those choices were insufficiently challenged. Understanding that failure is essential for any organization that believes its compliance program is robust.

Resources:

The Terrible Mess at Michigan Football, by Jason Gay, writing in the Wall Street Journal.

Ex-Michigan coach Sherrone Moore charged with home invasion, stalking, breaking—Austin Meek and Sam Jane writing in The Athletic.

Fire Everybody—Alex Kirshner, writing in Slate.

Source: Michigan begins a review of the athletic department, by Dan Wetzel and Pete Thamel, writing for ESPN.

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ACI FCPA Conference 2025

ACI Post Conference Reflections: Mike Huneke Insights on DOJ’s Trade Fraud Task Force and Tariff Enforcement

By special arrangement with ACI, I was able to record several participants, speakers, panelists, and moderators from the recently concluded ACI-FCPA and Global Anti-Corruption Conference held at the Gaylord near Washington, DC. This podcast details the guest’s experience at the event. In the second of our series, I visit with Mike Huneke from Morgan Lewis about the recent ACI FCPA and Global Anti-Corruption Conference.

We delve into the DOJ’s presence and announcements, particularly regarding the new Trade Fraud Task Force. Discussions include the robust focus on tariff enforcement, the implications for corporate compliance, and the need for companies to prepare for intensified scrutiny. The conversation also highlights changes from past FCPA frameworks to current practices. The episode offers valuable insights for those in the corporate compliance field, stressing the importance of being proactive and ensuring frontline staff are well informed about new enforcement priorities.

Key highlights:

  • Morning Panel Insights
  • DOJ’s Renewed Presence
  • Task Force and Enforcement Strategies
  • Compliance and Corporate Challenges
  • Conference Reflections and Community
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PodFest Expo 2026 Speaker Series Preview

Podfest Expo 2026 Speaker Preview Series: Dan R Morris on How to Market and Grow a Solo Narrated Podcast

In this episode of the PodfestExpo 2026 Speaker Preview Podcasts series, Tom Fox visits with Dan R Morris, host of the Tracing The Path podcast, and discusses his presentation at PodfestExpo 2026. Some of the highlights in this podcast are:

  • Dan’s role in the world of podcasting.
  • His presentation on ‘How to Market a Solo Narrated Podcast.’
  • What Dan hopes to get out of PodFest Expo 2026 and why you should attend.

I hope you can join us at Podfest Expo 2026, hosted by Podfest Global. This year’s event will be the 12th anniversary and will be held January 15-18, at the RENAISSANCE ORLANDO AT SEAWORLD® in Orlando, Florida. The lineup of this year’s event is simply first-rate, with some of the top names in podcasting.

Podfest Expo is a community of people interested in and passionate about sharing their voices and messages with the world through powerful audio and video mediums. We’re proud to unite as many people as possible to learn, get inspired, and grow better together.

Podfest Expo is so much more than just a conference. While we pride ourselves on featuring the most engaging speakers, exciting topics, and in-depth content, what sets the Podfest Expo event apart from all others is the tight-knit community we’ve been building since 2013. You don’t just attend a Podfest event—you become part of the Podfest family.

Whether you’re new to podcasting or a veteran podcaster looking to innovate and improve your podcast, our easy-to-understand Conference Topics allow you to customize a daily agenda based on what you’re most interested in learning. No matter your skill level or experience, Podfest Expo 2026 has plenty to offer!

Please join us at the event. For information on the event, click here. As an extra benefit for listeners of this podcast, Podfest Expo is offering 10% off any ticket level. Enter the discount code Fox2026 or visit this link.

Podfest Expo 2026 is a production of Podfest Global, which is the sponsor of this podcast series.

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Compliance Tip of the Day

Compliance Tip of the Day – Your Investigative Protocol

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 will consider issues relating to your internal investigations. Today, we begin by considering your investigative protocol.

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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AI Today in 5

AI Today in 5: December 15, 2025, The Good, Bad & Ugly Edition

Welcome to AI Today in 5, the newest edition of 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 four stories from the business world, compliance, ethics, risk management, leadership, or general interest about AI.

Top AI stories include:

  1. Data Sovereignty and AI compliance. (DataCentre)
  2. Trump’s EO cuts down on AI compliance. (Bitget)
  3. The Good, Bad & Ugly of AI. (WSJ)
  4. AI leaders eye breakthroughs. (Bloomberg)
  5. Swiss Re signs MoU to develop AI capabilities. (FinTechGlobal)

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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Daily Compliance News

Daily Compliance News: December 15, 2025, The End of the FCA 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:

  • 11th Circuit hears arguments invalidating the FCA. (Reuters)
  • The boss got drunk at the Christmas party. Yikes! (NYT)
  • SEC is weighing PCAOB changes. (WSJ)
  • The perils of AI in recruiting. (FT)

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

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FCPA Compliance Report

FCPA Compliance Report – Kristy Grant-Hart on the Evolution of Compliance in 2026: Navigating New Risks and Regulations

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Kristy Grant-Hart, Head of Advisory Services at Diligent’s Spark Compliance Group, to discuss where compliance has been in 2025 and where it is going into 2026.

Tom Fox and Kristy Grant-Hart explore the future of corporate compliance in 2026 and beyond. Key discussion areas include the Trump administration’s changing focus on the Foreign Corrupt Practices Act (FCPA), the designation of cartels as foreign terrorist organizations, and the implications for third-party due diligence. They also delve into modern slavery laws, the impacts of AI on compliance, and the necessity of a unified approach to compliance strategy.

Additionally, Kristy introduces the Compliance and Ethics Innovation Collective, a new program from Spark and Diligent that integrates services and software to deliver a more robust compliance solution. The session concludes with strategic advice for compliance officers on staying ahead of dynamic regulatory changes and maintaining effective risk management.

 

Resources:

Kristy Grant-Hart on LinkedIn

Diligent Website

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Blog

The Michigan Man, Part 1 – From Winning Program to Institutional Crisis

There are moments when an organization confronts a crisis so severe that it overwhelms every narrative it once controlled. The University of Michigan now finds itself in precisely that moment. What began as a continuation of compliance issues stemming from the sign-stealing scandal has rapidly escalated into something far more serious, far more painful, and far more destabilizing. This is no longer a story about NCAA rules or institutional embarrassment. It is a story about human failure, organizational breakdown, and the real-world consequences of ignoring warning signs.

As compliance professionals, our instinct is to move quickly to frameworks, root causes, and lessons learned. That work will come later in this series. But first, it is essential to set out the facts as they are currently known and to acknowledge the human cost embedded in every paragraph of this story. This story is far beyond compliance and ethics, but it is a true human tragedy. But it will also show how such a human tragedy could have been prevented if the basic tenets of organizational compliance and ethics had been followed.

All resources cited in this four-part series are listed at the end of this blog post. Finally, this writing is personal, as I am a UM graduate.

The Rise of Sherrone Moore

Sherrone Moore’s ascent within the University of Michigan football program appeared, at least on the surface, to be a model of internal succession. Moore joined Jim Harbaugh’s staff in 2018 and rose steadily through the ranks, ultimately serving as offensive coordinator during Michigan’s 2023 national championship season. When Harbaugh departed for the NFL, Moore was promoted to head coach, a decision widely praised as ensuring continuity and stability.

Moore was not simply a coach. He was a symbol. His emotional post-game interview after a victory over Penn State, while Harbaugh was suspended, became an iconic moment for Michigan fans. He embodied loyalty, perseverance, and what many referred to as the “Michigan Man” ethos. ESPN

Yet even at the time of his promotion, Moore’s record was not unblemished. He had already been implicated in the Connor Stalions sign-stealing investigation and had received NCAA suspensions for deleting text messages during that inquiry. Those issues were treated by the university and much of the fan base as technical compliance matters rather than as indicators of deeper governance or integrity risks. Slate

That framing now appears deeply flawed.

The Inappropriate Relationship Investigation

According to reporting by The AthleticESPNSlate, and The Wall Street Journal, the University of Michigan received an anonymous tip earlier in 2025 alleging an inappropriate relationship between Moore and a female football staffer. The university retained Jenner & Block, an outside counsel, to conduct an investigation. Initially, both Moore and the staffer denied any relationship, and investigators reported that insufficient evidence existed to substantiate the claim.

That changed dramatically in December 2025. Prosecutors allege that the staffer disclosed corroborating evidence confirming a multi-year intimate relationship after she ended it earlier that week. At that point, the university determined that Moore had violated institutional policy and terminated him for cause, avoiding a reported $14 million buyout. The Athletic

This was not merely an employment decision. It was the spark that ignited a cascading crisis.

The Criminal Charges

Within hours of his dismissal, Moore’s personal situation escalated into a criminal matter. Prosecutors allege that Moore went to the staffer’s residence without permission, entered through an unlocked door, and engaged in a confrontation during which he picked up scissors and butter knives and threatened to harm himself. According to court statements, Moore allegedly made repeated statements such as “I am going to kill myself” and “My blood is on your hands. The Athletic

Moore was subsequently charged with felony third-degree home invasion and misdemeanor charges of stalking and breaking. He was taken into custody, evaluated at a hospital, and later released on bond with GPS monitoring and a requirement that he continue mental health treatment. A probable cause hearing is scheduled for January 2026.

At this point, it bears stating plainly: these are allegations, and Moore has pleaded not guilty. The legal process will determine criminal responsibility. However, from an organizational perspective, the damage has already been done.

The Expanding Institutional Investigation

What began as an inquiry into Moore’s conduct has now broadened into a comprehensive review of the University of Michigan athletic department. University leadership has confirmed that Jenner & Block’s mandate has expanded to examine how the athletic department handled the Moore matter and other recent scandals, including the sign-stealing investigation and prior misconduct by football staffers. ESPN

Interim President Domenico Grasso has publicly called for anyone with relevant information to come forward, emphasizing that “all of the facts here must be known.” Athletic Director Warde Manuel remains in his position for now, but multiple reports note that his leadership and oversight are under intense scrutiny.

This expansion matters. It signals that the university itself recognizes that Moore’s actions cannot be isolated from the environment in which they occurred.

Beyond Compliance: The Human Tragedy

It would be a profound mistake to reduce this story to a checklist of policy violations.

At the center of this crisis are people whose lives have been irreversibly altered. Moore is a married father of three whose career has collapsed in public view. His family faces humiliation, uncertainty, and emotional trauma that will not disappear with headlines. Prosecutors describe the staffer at the center of the allegations as someone who felt terrorized and unsafe, a position no employee should ever occupy. University of Michigan players have lost their head coach midseason, forcing them to process personal loyalty, public scandal, and institutional chaos simultaneously. There is also the culture of an entire university athletic department, which not only allowed such behavior but also tolerated and even celebrated it by promoting Moore to Head Coach.

The broader Michigan community, alumni, students, and fans are also stakeholders in this tragedy. For an institution that has long traded on its image of integrity and moral leadership, the reputational damage cuts deeply. Being a ‘Michigan Man’ was meant to stand for something—something positive, that you did things in the right way, and you personally held yourself to a higher standard. As The Wall Street Journal observed, this is no longer a college football story. It is “agony in Ann Arbor. I certainly echo that feeling personally.

A Pattern, Not an Anomaly

The most troubling aspect of the facts as currently known is how familiar they feel. The Moore scandal follows a series of incidents involving Michigan athletics over recent years, including the Stalions’ sign-stealing operation, multiple staff arrests, internal HR complaints, and even a federal indictment of a former assistant coach for accessing student-athletes’ private data. WSJ

The issue may not be any single actor but rather an entrenched culture that has historically insulated powerful figures from accountability. Slate: When organizations repeatedly frame misconduct as isolated events, they fail to confront systemic risk.

Why This Matters for Compliance Professionals

For compliance professionals, this case is already instructive even before we reach lessons learned. It demonstrates how compliance failures often emerge not as sudden collapses but as accumulations of ignored signals. It shows how reputational capital built over decades can evaporate in a matter of days. Most importantly, it reminds us that behind every policy failure are human beings who bear the consequences.

While there will be others who say ‘I told you so’ or want to bring the vaunted Michigan Man down a peg or two, the lessons from this scandal and human tragedy are no less important for your team, your school, and your university.

In the next installment of this series, I will turn directly to Sherrone Moore’s individual compliance and ethics violations, including his conduct during the sign-stealing investigation and his alleged misrepresentations to investigators. That analysis is necessary. But it should never obscure the reality that this story is about far more than rules. Compliance exists to protect people, institutions, and trust. When it fails, the cost is measured not only in fines or sanctions but also in lives disrupted and communities shaken.

Resources:

The Terrible Mess at Michigan Football, by Jason Gay, writing in the Wall Street Journal.

Ex-Michigan coach Sherrone Moore charged with home invasion, stalking, breaking—Austin Meek and Sam Jane writing in The Athletic.

Fire Everybody—Alex Kirshner, writing in Slate.

Source: Michigan begins a review of the athletic department, by Dan Wetzel and Pete Thamel, writing for ESPN.

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Sunday Book Review

Sunday Book Review: December 14, 2025, The Best Books on Business Edition

In the Sunday Book Review, Tom Fox considers books that would interest compliance professionals, business executives, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. Today, we continue our review of some years’ top books in various categories as curated by the Financial Times. In this episode, we look at a book by Andrew Hill on business.

  • Make Work Fair by Iris Bohnet and Siri Chilazi
  • House of Huawei by Eva Dou
  • The Thinking Machine by Stephen Witt
  • The New Geography of Innovation by Mehran Gul
  • Your Life is Manufactured by Tim Minshall

Resources:

Best Books of 2025: Business by Andrew Hill

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending December 13, 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 you the compliance stories you need to know 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. AI architects are Time’s Person of the Year, Disney licenses figures to Sora AI for use, McDonald’s pulls AI-created Christmas ads, AI hackers are getting very good at it, and NAACP presses for equity-first AI in healthcare.

This week’s stories include:

  • DOJ folds another set of corruption convictions. (ESPN)
  • Bessent wants DOT to take over all AML roles. (WSJ)
  • US credibility in countering corruption is under strain. (JustSecurity)
  • Nadine Menendez wants her jewelry back. (4NBCNY)
  • China executes a second banker over corruption. (Bloomberg)
  • EU fines X $140MM. (WSJ)
  • Zelensky’s sabotage of oversight; you can see the results. (NYT)
  • UK to crack down on bankers, lawyers, and accountants involved in money laundering. (Bloomberg)
  • Nepal accuses China of corruption over the airport. (NYT)
  • Trump to pre-empt state laws on AI. (Reuters)

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.⁠