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Word of the Week

Word of the Week with Kenneth O’Neal – Exploring ‘Interest’ and Meaningful Conversations

Each week, Kenneth O’Neal discusses a word that describes a principle or value of the Qualities of Success. We suggest that you incorporate the Word of the Week into your thoughts, deeds, and actions. You might currently possess the quality and desire to develop it to a higher level. You could replace a bad habit with a good habit. Write an action step and use it daily to develop the quality in your life. In this episode, Kenneth discusses the word – Interest.

In this episode, Rick and Kenneth delve into the concept of ‘interest’ as both a noun and a verb, exploring its various meanings and applications. The conversation navigates topics such as effective communication and the importance of maintaining open dialogues on significant matters, including religion and politics, despite potential disagreements. A poignant story about a trip to Rwanda highlights the depth of human connection and service, illustrating that true giving often means carrying the hearts and stories of others with us. Join us for a thought-provoking discussion that encourages curiosity, empathy, and continuous conversation.

Key highlights:

  • Word of the Week: Interest
  • Deep Dive into Effective Communication
  • The Importance of Conversations
  • A Personal Story from Rwanda

Resources:

KRONEAL Consulting

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Innovation in Compliance

Innovation in Compliance – Allison Lagosh on Proactive Compliance Planning for Regulatory Changes

Innovation is present in many areas, and compliance professionals must not only be prepared for it but also actively embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox visits with Allison Lagosh, Head of Compliance at Saifr.ai, to discuss the current and future landscape of regulatory compliance.

With over two decades of experience in asset management, compliance, and regulatory affairs, Lagosh anticipates a pivotal shift towards AI and cryptocurrency regulations. She predicts a lighter enforcement landscape but stresses the importance of a conservative, informed approach to compliance, encouraging firms to future-proof their programs by staying abreast of regulatory changes and engaging in cross-team collaboration. Her insights, shared on platforms like the “Innovation in Compliance” podcast, highlight the necessity of strong leadership support and continuous learning to effectively navigate the dynamic regulatory environment, particularly in the realm of emerging technologies.

Key highlights:

  • Regulatory Futurism: AI and Crypto Compliance
  • “Colorado’s Groundbreaking AI Safety Legislation”
  • Proactive Compliance Planning for Regulatory Changes
  • Navigating Compliance Uncertainties with AI Integration
  • Regulatory Insights on Safer.AI Website

Resources:

Allison Lagosh on LinkedIn

Saifr.ai

Tom Fox

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Check out my latest book, Upping Your Game—How Compliance and Risk Management Move to 2023 and Beyond, available from Amazon.com.

Innovation in Compliance was recently honored as the number 4 podcast in Risk Management by 1,000,000 Podcasts.

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Red Flags Rising

Red Flags Rising: S01 E19 – Stack Sweeps, Successor Liability, and “Knowledge” – Emerging Signals from Recent Enforcement Actions

Mike & Brent coin a new phrase in the context of white-collar corporate enforcement, “stack sweep,” to describe the potential enforcement risks–up and down the technology stack–that recent U.S. export controls settlements, policy statements, and guidance portend in focusing on broad end-use or end-user “catch-all” provisions that turn on “knowledge” defined to include “an awareness of a high probability.” Specifically, they discuss how two recent cases are short on facts but long on lessons (or, as Brent says, appear at first glance to be “dogs”) (01:07), discuss the Alpha & Omega Semiconductor (AOS) settlement announced July 2, 2025 (03:19), how reliance on the advice of counsel is as useful as the extent of facts disclosed to counsel (06:09), discuss the Unicat Catalyst Technologies settlement announced by the Bureau of Industry & Security (BIS) on June 24, 2025 and parallel settlements announced by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Justice’s (DOJ’s) National Security Division (NSD) on June 16, 2025 (08:34), the lessons for pre-acquisition due diligence (11:03) including the importance to buyers of testing whether a target’s trade compliance program incorporates risks driving by the full definition of knowledge to include “high probability” awareness (for example, by specifically addressing risks under the catch-all provisions) (15:33), convergence across DOJ, Treasury, and Commerce regarding expectations for corporate compliance programs (17:50), and then Mike & Brent coin the phrase “stack sweep” to describe what would be the equivalent in corporate export controls enforcement to prior “industry sweeps” in corporate FCPA enforcement, in that catch-all, knowledge-driven end-use and end-user enforcement “sweeps” within the tech industry would be “sweeps” up and down the relevant technology stack (20:01). They then conclude with Brent’s back-by-popular-demand segment, “Managing Up” (25:52).

Resources:

The July 2, 2025, BIS settlement with Alpha & Omega Semiconductor

The June 24, 2025, BIS settlement with Unicat Catalyst Technologies

The June 16, 2025, OFAC settlement with Unicat Catalyst Technologies

The June 16, 2025, DOJ NSD press release with the relevant declination letter (buyer), non-prosecution agreement (target), and criminal guilty plea (former CEO)

For everything you ever wanted to know about the “high probability” standard

Brent LinkedIn

Mike LinkedIn

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SBR - Authors' Podcast

SBR-Authors Podcast: The Resilience of the Human Spirit: Ana Hebra Flaster’s Immigrant Story and the Essence of Liberty

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 interviews author Ana Hebra Flaster about her book ‘Property of the Revolution‘ and her journey as an immigrant from Cuba to the United States

Flaster shares her experiences from childhood, the impact of her sudden move from Cuba, and how it shaped her perspective on liberty and resilience. She details her family’s struggles and triumphs, providing a personal window into the broader Cuban exodus. The conversation also touches on her writing process, the role of storytelling in preserving her family’s legacy, and the importance of immigrants to American culture and innovation. Flaster emphasizes the value of freedom, the trauma of displacement, and the enduring strength of the immigrant spirit. Ultimately, she discusses her ongoing efforts to raise awareness about Cuban history and current events through her writing.

Key highlights:

  • Ana Hebra Flaster ‘s Childhood and Immigration Story
  • The Concept of Liberty
  • Storytelling and Family Resilience
  • Writing Process and Challenges
  • Role of PR and Final Thoughts

Resources:

Ana Hebra Flaster at PR by the Book

Property of the Revolution: From a Cuban Barrio to a New Hampshire Mill Town—A Memoir on Amazon & Bookshop.org

Ana Hebra Flaster Website

PR by the Book Website

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All Things Investigations

All Things Investigation – Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner

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 Daniel Weiner to discuss a complex legal case involving a valuable Picasso painting.

Weiner is the Chair of Hughes Hubbard & Reed’s Litigation Department, Chair of the Complex Business Disputes practice, and a partner in the International & Domestic Arbitration and Intellectual Property Disputes groups. Daniel and Tom take a deep dive into the intricate details of how a series of fraudulent transactions led to a multimillion-dollar dispute over Picasso’s ‘Le Peintre.‘ The podcast highlights the importance of thorough due diligence in the art world and examines the legal complexities involved in resolving such cases. As they unravel the story, they highlight the crucial role of investigations in preventing art fraud and safeguarding ownership rights.

Key highlights:

  • The Fascinating Picasso Case
  • The Fraud Unveiled
  • Legal Issues and Investigations
  • Discovery Disputes and Court Proceedings
  • Consulting and Due Diligence in Art Law

Resources:

Daniel Weiner

Hughes Hubbard & Reed website

HHR Client Alert: Firm Obtains Discovery Win in Dispute Over Sale of Pablo Picasso Painting

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The Ethics Experts

Episode 222 – Pat Poitevin

In this episode of The Ethics Experts, Nick welcomes Pat Poitevin.

Mr. Pat Poitevin is an internationally recognized expert in anti-corruption, corporate ethics, and compliance. He is the co-founder and executive director of the Canadian Centre of Excellence for Anti-Corruption (CCEAC). He is also co-founder & CEO of the boutique advisory firm Active Compliance and Ethics Group (ACEG). Mr. Poitevin is a 35-year veteran of the Royal Canadian Mounted Police and retired in October 2017, where he was the RCMP’s anti-corruption and compliance expert. He has also been an investigator and expert on drugs, organized crime, and financial crime. He is in demand as a speaker, university lecturer, and trainer at the international level and has extensive experience in program development and capacity building. Mr. Poitevin has been advising and helping public and private organizations to improve their ethics, compliance, and anti-corruption measures. Mr. Poitevin has also worked on research, consultative, and advisory projects with the G20, UNODC, and the IMF. He was a member of the Canadian Project Committee (PC278) involved in the development of the ISO 37001 Anti-bribery and ISO 37002 Whistleblowing Management systems standard, as well as ISO 42001 AI Management systems. He is a member of the Transparency International Expert Network, ACFE, IAFCI, AACI, and several other professional associations. He also has the CACM and TASA professional designations. He is a member of Transparency International Canada and a Certified Anti-Corruption Manager (CMAC-USA).

Connect with Pat on LinkedIn

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Corruption, Crime and Compliance

Refocusing Due Diligence on Cartel and TCOs

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators, global companies must prepare for heightened scrutiny. Michael breaks down the mounting risks, enforcement priorities, and practical steps companies must take to protect themselves from becoming unwitting participants in criminal operations.

You’ll hear him discuss:

  • How DOJ’s new two-pronged enforcement strategy is bringing corporate facilitators of cartels and TCOs into the crosshairs
  • Why traditional due diligence no longer goes far enough, especially with “Nth Party” risks buried deep in supply chains
  • How cartels and TCOs exploit legitimate businesses in sectors like logistics, agriculture, mining, and construction
  • The importance of identifying beneficial ownership and tracing complex corporate structures across jurisdictions
  • Red flags to watch for, from nominee arrangements and shell companies to unexplained wealth and layered financial flows
  • How cartels are adapting with fake websites, fake bios, and cryptocurrency to mask illicit activities
  • What companies must do to modernize their compliance systems with open-source tools and workflow automation
  • Why trade-based money laundering, remittance services, and decentralized platforms are growing areas of concern

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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Compliance Tip of the Day

Compliance Tip of the Day – COSO Governance Framework: Part 1, Introduction

Welcome to “Compliance Tip of the Day,” the podcast where we bring 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, 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.

Today, we introduce a multi-part review of the new COSO Governance Framework (CGF). 

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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Adventures in Compliance

Adventures in Compliance: The Novels – The Hound of the Baskervilles: Uncovering Compliance – Lessons from The Hound of the Baskervilles

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into the Sherlock Holmes novels. Over this season Tom will take a deep dive into each novel over 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. For the month of July we are considering lessons from The Hound of the Baskervilles.

Fiona and Timothy are back to extract five key compliance lessons from the story, including combating complacency, effective data use, maintaining objectivity, transparent communication, and ethical culture. These principles, drawn from a Victorian mystery, prove profoundly relevant for modern corporate compliance.

Highlights include:

  • Overview of Compliance Lessons from Sherlock Holmes
  • Lesson 1: Avoiding Complacency
  • Lesson 2: Power of Effective Data and Evidence
  • Lesson 3: Independence and Objectivity
  • Lesson 4: Transparent Communication and Reporting
  • Lesson 5: Importance of Culture and Ethics

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

Sherlock Holmes, The Novels, with an introduction by Michael Dirda

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FCPA Compliance Report

FCPA Compliance Report – Ethical Challenges in AI, Data Protection, and Sports with André Paris

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes back André Paris for an insightful discussion on various ethical challenges in today’s world. André revisits his role in compliance and ethics and provides updates on his work since the pandemic and delves into the issues of algorithmic bias, transparency, and the ethical ramifications of AI systems, particularly in surveillance and privacy. André also shares his experience as a PhD candidate researching AI’s impact on civil liberties. The episode further explores the ethical challenges in the sports industry, including corruption, doping, and harassment. Lastly, André talks about his book ETHICS & TRANSPARENCY: A Path To Compliance on Amazon and its practical applications in fostering an ethical corporate culture.

Key highlights include:

  • André‘s Role in Compliance and Ethics
  • Ethics and Transparency: André’s Book
  • The Rise of AI and Ethical Challenges
  • AI in Business and Research Applications
  • Data Protection as a Civil Liberty
  • Ethical Challenges in Sports

Resources:

André Paris on LinkedIn

ETHICS & TRANSPARENCY: A Path To Compliance on Amazon

André Paris Website

Tom Fox

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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.