Categories
Corruption, Crime and Compliance

Current Developments in AI and Risk Management with Christian Focacci

Is AI a magic bullet – or just another tool in the compliance toolkit?

What really happens when you let algorithms near your risk decisions?

In this episode of Corruption, Crime and Compliance, Christian Focacci, founder and CEO of Threat.Digital, returns for a thoughtful and highly practical conversation about the state of artificial intelligence in compliance and third-party risk management. Christian’s platform is at the forefront of using large language models and real-time data to transform how companies identify and manage risk – without losing sight of the human judgment that still needs to guide every decision. He and Michael explore what’s changed in the AI landscape over the past year, what’s misunderstood about the technology, and how compliance teams can strike the right balance between innovation and accountability.

You’ll hear them discuss:

  • Why Christian believes you shouldn’t use AI unless it’s truly the right tool for the job, and how this philosophy shapes how Threat.Digital builds and deploys its systems
  • What large language models actually are, how they function under the hood, and why most people fundamentally misunderstand how they learn and process information
  • The growing demand for corporate AI governance, how some risk committees are creating unnecessary delays, and why many internal processes are still focused on the wrong questions
  • How Threat.Digital uses AI to reduce noise in due diligence, replacing bloated, unfiltered search results with clear, high-quality summaries supported by verifiable sources
  • Why the real power of AI isn’t about replacing humans, but about expanding what can be reviewed – moving from 10 data points to 10,000, while helping compliance professionals focus only on what matters
  • The future of due diligence: chaining AI tasks to build multi-layered investigations that trace ownership, pull third-party records, and surface hidden risks in real time
  • How AI is revolutionizing name screening and sanctions checks by eliminating irrelevant fuzzy matches, freeing teams from chasing meaningless alerts and allowing them to act on true risks with confidence

Resources

Christian Focacci on the Threat.Digital | LinkedIn | Email: chris@threat.digital

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Career Can D0

Business Wisdom from Golf with Joe Bronson

What can golf teach us about business, leadership, and personal growth? A lot more than you might think. In this special episode of Career Can Do, Chris Sandland, Director of Operations at Faremouth & Company, steps in as our host, Mary Ann. Chris sits down with Joe Bronson, CEO of The Bronson Group and author of books Golf Chronicles, Through The Green, and Pardon Me. 50 Years of Gold, One Hole at a Time. With decades of experience in both the boardroom and on the golf course, Joe shares stories and insights that show how the game mirrors life, from ethics and decision-making to handling setbacks and building relationships.

Joe has played 93 of the top 100 golf courses in the U.S. and even had the once-in-a-lifetime experience of playing a round with golf legend Arnold Palmer. But beyond the prestige and unforgettable moments, Joe sees golf as a powerful tool for connection and leadership development. Whether he’s navigating a challenging par three or a major business decision, the mindset is often the same: know your skill set, take smart risks, and stay focused on the present.

He explains, “In business, just like in golf, emotion can ruin you. You have to keep things in balance, stay disciplined, and respond to the situation in front of you, not the one behind you.”

Chris and Joe also explore how golf can still be a relevant networking tool, even in today’s digital-first world. Joe argues that spending four hours on a course with someone tells you more about them than a dozen Zoom meetings ever could. And he’s seen firsthand how a well-timed piece of advice from someone who believes in you, even a caddie, can shift your entire approach.

Now retired from corporate life, Joe focuses on giving back. All proceeds from his book support youth golf and university programs, including The First Tee, which helps underprivileged kids learn the game while gaining life skills.

If you’re a leader, a golfer, or just someone trying to make good decisions in work and life, this episode offers timeless lessons, and a few great stories, from someone who’s walked both the fairway and the executive floor.

Resources

Joe Bronson on the Web | Buy Joe’s Books on Amazon

Chris Sandland on LinkedIn

Categories
All Things Investigations

All Things Investigations – Navigating New DOJ Directives: Declinations, Cooperation, and Whistleblower Programs with Mike DeBernardis and Katherine Taylor

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR lawyers Mike DeBernardis and Katherine Taylor about the recent speech by Matthew R. Galeotti, Head of the Criminal Division at the U.S. Department of Justice (DOJ);  his attendant Memo entitled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime; and the updates to the Corporate Enforcement and Voluntary Self-Disclosure Policy; and finally the new Memo on Monitors and Monitorships.

Key highlights:

  • Is meaningful cooperation credit finally here?
  • Did we move from a presumption of a declination to something stronger or at least more tangible?
  • Is the Kenneth Polite “double secret—we know it when we see it” cooperation requirement now a thing of the past, or at least defined?
  • Enhancements to the Whistleblower Program—Initial Thoughts.
  • Monitors—dead and gone or something else?
  • What, if anything, does this change about the role of corporate compliance today?

Resources:

Mike DeBernardis

Hughes Hubbard & Reed website

Katherine Taylor

Categories
Daily Compliance News

Daily Compliance News: June 16, 2025, The Golden Share 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, and general interest, all relevant to the compliance professional.

Top stories include:

  • The US now has a golden share of US Steel. (NYT)
  • Will Mike Madigan be sentenced to 7.5 years? (NYT)
  • The DOJ whistleblower program focuses on healthcare fraud. (Reuters)
  • A Congolese customs officer was beaten for anti-corruption efforts. (AP)
Categories
FCPA Compliance Report

#Risk New York Speaker Series – AI Investments and Political Uncertainty with Chris Mason

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration.

At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals.

In this episode, Tom Fox talks with Chris Mason, who recently launched his risk advisory practice, Woodhorn Global, focusing on due diligence investigations. Chris shares insights about his upcoming presentations at the #RiskGRC conference in July, focusing on AI investments and the impact of political uncertainty on the GRC (Governance, Risk, and Compliance) community. They discuss the significance of AI in the field and the importance of adapting to political changes. Chris also emphasizes the value of in-person events in understanding best practices and navigating the evolving risk landscape.

Resources:

#Risk Conference Series

#RiskNYC—Tickets and Information

Chris Mason on LinkedIn

Categories
Adventures in Compliance

Adventures in Compliance: The Novels: Data Analytics from The Sign of Four

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into the Sherlock Holmes novels. Throughout this season, Tom will explore each novel in a four-part series. The four novels we will consider from the ethics and compliance perspective are A Study in Scarlet, The Sign of Four, The Hound of the Baskervilles, and The Valley of Fear. We continue our four-episode series on the second novel, The Sign of Four, by reviewing how Holmes uses data analytics and pattern recognition in this story.

Timothy and Fiona had so much fun last week that they are back to explore how the methods of the fictional detective Sherlock Holmes can be applied to modern compliance work. By examining the principles from ‘The Sign of Four,’ they take a deep dive into five key lessons that can sharpen the skills of compliance professionals today: the art of discernment, establishing baselines, contextual analysis of data, leveraging technology, and continuous refinement and learning. Their discussion highlights how these timeless analytical approaches, when amplified by modern technology, provide a robust framework for dealing with complex and rapidly changing compliance landscapes.

Highlights include:

  • Applying Holmes’ Methods to Compliance Analytics
  • Lesson 1: The Art of Discernment
  • Lesson 2: Establishing Baselines
  • Lesson 3: Contextual Analysis of Data
  • Lesson 4: Leveraging Technology and Tools
  • Lesson 5: Continuous Refinement and Learning
  • Conclusion: Balancing Timeless Principles with Modern Adaptability

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

Connect with Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
FCPA Compliance Report

FCPA Compliance Report – Recent DOJ Policy Announcements

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes back James Tillen and Ann Sultan, both partners at Miller & Chevalier, and takes a deep dive into four recent DOJ policy announcements: FCPA Enforcement, White-Collar Enforcement, Criminal Enforcement Policy, and the Whistleblower Pilot Program.

They take a deep dive into Deputy Attorney General Todd Blanche’s memo on Investigations and Enforcement of the FCPA, reviewing the stated main goals of the DOJ and how prosecutors are supposed to achieve these goals. They also consider three directives to prosecutors: focus on cases involving individual misconduct, proceed expeditiously, and consider the collateral consequences. They also examine the White Collar Plan and CEP and ask if we have shifted from a presumption of declination to a more tangible framework and conclude by reviewing what compliance professionals need to consider and investigate now.

Key highlights include:

  • How does the principle of “not attribute[ing] nonspecific malfeasance to corporate structures” impact potential prosecutions of companies and individuals?
  • And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations?
  • What does it mean for companies that the DOJ is prioritizing “serious misconduct”?
  • What are the implications of the DOJ’s stated intent to avoid penalizing “routine business practices in other nations”?
  • Do you see this as a shift in focus for the DOJ to non-US companies?
  • Other DOJ Priorities & Announcements
  • Policy Shifts and Clarifications
  • Looking Ahead: What’s on the Horizon

Resources:

FCPA Spring Review 2025 – Miller & Chevalier

DOJ Criminal Division White Collar Plan

Guidelines for Investigations and Enforcement of the FCPA

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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

Categories
Blog

Investigative Lessons from Sherlock Holmes: The Sign of Four

Corporate compliance and Sherlock Holmes may seem worlds apart, but compliance professionals and Sir Arthur Conan Doyle’s legendary detective share a core responsibility: uncovering truths hidden behind complex webs of evidence. “The Sign of Four,” one of Doyle’s most gripping Sherlock Holmes tales, offers powerful investigative insights directly applicable to the realm of compliance. Here are five key lessons compliance professionals can draw from Holmes’s investigative methods in this classic novel.

1. Precise Documentation: “Methodical Observation”

In The Sign of Four, Sherlock Holmes emphasizes the importance of methodical and precise documentation as crucial to solving complex mysteries. Early in the narrative, Holmes carefully examines a mysterious note received by Miss Mary Morstan. His meticulous observation of handwriting, paper quality, and ink composition enables him to deduce the note’s origin and purpose, thereby setting the course of the investigation.

Compliance professionals should emulate Holmes by rigorously documenting every aspect of an investigation to ensure thoroughness and accuracy. Precise records of evidence, witness statements, and procedures ensure accuracy, accountability, and transparency, significantly reducing risks of oversight or misinterpretation. Proper documentation also strengthens the organization’s ability to respond effectively during audits or regulatory inquiries.

2. Logical Analysis: “Eliminating the Impossible”

Holmes famously asserts in The Sign of Four, “When you have eliminated the impossible, whatever remains, however improbable, must be the truth.” This principle guides his pursuit of justice throughout the novel. Holmes methodically rules out improbable scenarios in investigating the disappearance of Captain Morstan and the subsequent quest for hidden treasure, ultimately unveiling Jonathan Small’s elaborate revenge-driven plot.

Compliance officers should similarly use structured analytical frameworks to eliminate false assumptions and unsubstantiated theories during investigations. Adopting logical, disciplined analysis reduces biases, prevents costly mistakes, and fosters more accurate and actionable outcomes. Holmes’s deductive approach encourages compliance professionals to remain vigilant against assumptions that may cloud judgment.

3. Embrace Collaboration: “Leveraging Complementary Strengths”

In The Sign of Four, Sherlock Holmes frequently relies on Dr. Watson’s support and complementary skills. Watson’s medical knowledge and practical insights greatly assisted Holmes during the investigation, notably during examinations of crime scenes and understanding the emotional motivations of suspects and victims.

For compliance professionals, this illustrates the importance of multidisciplinary collaboration. Effective compliance investigations often require collaboration with professionals from diverse specialties, including auditors, forensic accountants, legal advisors, human resources specialists, and IT experts. Embracing a collaborative approach ensures a comprehensive investigation, as each discipline brings unique insights that enhance the overall effectiveness and credibility of the compliance function.

4. Attention to Subtle Indicators: “Noticing Small Clues”

Holmes’s brilliance often lies in noticing seemingly insignificant details overlooked by others. In The Sign of Four, Holmes carefully notes tiny footprints, peculiar scents, and minor discrepancies in testimonies, each subtly directing the investigation toward its resolution. For instance, Holmes’s keen attention to Toby, the trained bloodhound, and his reaction to specific scents help locate key evidence pivotal to unraveling the mystery.

Compliance professionals must likewise sharpen their observational skills to detect subtle indicators of wrongdoing, such as minor financial discrepancies, slight variations in employee behaviors, or seemingly inconsequential procedural anomalies. Often, the most significant compliance breaches initially manifest as minor irregularities. Developing Holmes-like attentiveness can significantly enhance the detection and early resolution of compliance issues.

5. Managing Bias and Assumptions: “Maintaining Objective Judgment”

Throughout, Holmes maintains rigorous objectivity, avoiding emotional biases or ungrounded assumptions. Even when emotionally involved characters, including Watson and Miss Mary Morstan, draw emotional or intuitive conclusions, Holmes insists on relying exclusively on factual evidence and logic. His disciplined approach ensures accuracy and fairness in the investigation’s outcome.

Compliance officers frequently confront emotionally charged scenarios or influential stakeholders, which can pressure outcomes. Maintaining an objective and unbiased judgment is crucial to upholding fairness and integrity during compliance investigations. Holmes’s unwavering dedication to evidence-based analysis exemplifies the importance of unbiased fact-finding in safeguarding organizational ethics and compliance integrity.

Final Thoughts: Integrating Sherlock Holmes’s Methods into Compliance

The Sign of Four offers rich investigative wisdom that is directly applicable to corporate compliance. Sherlock Holmes’s meticulous documentation, disciplined logical reasoning, strategic collaboration, precise attention to detail, and uncompromising objectivity represent invaluable investigative methodologies for today’s compliance professionals.

As compliance continues evolving in complexity and significance, adopting Holmesian investigative rigor enhances our ability to protect organizational integrity, mitigate risks, and ensure regulatory compliance. Compliance professionals who master these investigative practices not only improve their effectiveness but also significantly contribute to their organization’s overall resilience and ethical standing.

In the dynamic landscape of corporate compliance, Sherlock Holmes’s timeless investigative lessons remain as relevant today as in Victorian London, reminding us that excellence in investigation demands continual refinement, unwavering diligence, and precise analytical clarity.

Categories
Compliance Tip of the Day

Compliance Tip of the Day – New FCPA Enforcement Memo-What Does it Say?

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 concise, 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.

 

Today, we begin a two-part look at the recently released FCPA Enforcement Memo. Today, in Part 1, we consider what it says. 

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

Categories
Sunday Book Review

Sunday Book Review: June 15, 2025, The Books on Corporate Governance 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. Today, we look at four new books on corporate governance for the summer of 2025.

 

  • On Board: The Modern Playbook for Corporate Governance by Jonathan Foster
  • Corporate Governance for New Directors: The Basics and Beyond by Michael L. Whitener, Robert N. Walton, and Blake Redding
  • Boardroom Blitz: Mastering the Art of Corporate Governance by Hendrith Vanlon Smith Jr.
  • Charged Governance: Transformative Governance Principles for Private Businesses by Andrew Usuki

The Sunday Book Review was recently honored as one of the Top 100 Book Podcasts.