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Adventures in Compliance

Adventures in Compliance – Institutional Justice and Institutional Fairness Lessons from The Adventure of the Veiled Lodger

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into Arthur Conan Doyle’s Sherlock Holmes collection, The Case-Book of Sherlock Holmes. It is the final set of twelve Sherlock Holmes short stories, first published in the Strand Magazine between October 1921 and April 1927. In this episode, we consider the story The Adventure of the Veiled Lodger.

Tom emphasizes the importance of fairness and transparency in compliance investigations, accountability without retaliation, encouraging whistleblowers, and addressing systemic failures. The episode also highlights how ethics and compliance must be ingrained in corporate culture, reflecting principles from the Department of Justice’s 2020 and 2024 updates to the Evaluation of Corporate Compliance Programs. Through Holmes’ empathetic approach, compliance professionals can learn the importance of contextual investigations and the pursuit of institutional justice. Tom invites Sherlock Holmes enthusiasts to engage in discussions about the stories and underscores the role of compliance in fostering a fair and ethical workplace.

Highlights include:

  • The Story of the Veiled Lodger
  • Lessons on Institutional Justice and Fairness
  • Lessons for CCOs

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

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Daily Compliance News

Daily Compliance News: February 17, 2025, The Cancel The Leases 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:

  • Retaliation? Musk and DOGE want to cancel federal judiciary leases. (Reuters)
  • DOJ guts bringing of corruption cases. (CNN)
  • Barclay faces a money-laundering investigation. (WSJ)
  • Is settling litigation paying a bribe? (WSJ)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out the FCPA Survival Guide on Amazon.com.

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FCPA Compliance Report

FCPA Compliance Report – National Security and Legal Perspectives with Kevin Carroll

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Kevin Carroll, now a partner at Fluet, to discuss national security issues to date under the Trump Administration.

Kevin Carroll discusses his move to Fluet Law, a national security law firm. He delves into the ongoing chaos in national security, ranging from employees’ concerns over legal processes at the Agency for International Development and the FBI to the unprecedented moves of the Trump administration in reprioritizing enforcement efforts. Kevin emphasizes the criticality of maintaining international alliances and intelligence-sharing, especially amidst controversial DOJ staffing and enforcement decisions. They also touch on the potential ramifications for U.S. companies engaged in foreign trade and anti-corruption enforcement. Don’t miss Kevin’s expert insights on the delicate balance of national security and legal frameworks in uncertain times.

Key highlights:

  • Kevin’s New Professional Chapter
  • National Security Concerns
  • Law Enforcement Priorities
  • International Relations and Security
  • Corporate Legal Risks Abroad
  • USAID and Export Control

Resources:

Kevin Carroll on LinkedIn

Fluet

Kevin Carroll on Fluet Law

Tom Fox

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Blog

Upping Your Compliance Game, Part 1 – The Business Case for Compliance: How Ethics and Compliance Drive Profitability

The Trump Administration has suspended FCPA enforcement for the foreseeable future. What does that mean for compliance professionals? Hui Chen has suggested this should be seen as an opportunity for compliance, but to do so, “It’s time to up your game . . . Instead of selling insurance for FCPA enforcement, become leaders that help your organizations perform.” Based on this challenge by the most imminent compliance commentator, I will devote this week’s blog posts to ways compliance professionals can up their collective game. Today, I demonstrate that effective compliance equates to more efficient business processes and great Return on Investment (ROI).

We are now at a point where sufficient data, academic research, and real-world case studies make one thing abundantly clear: a strong ethics and compliance program is not just good for business; it can now be seen as a driver of profitability. While compliance has long been seen as a necessary cost of doing business, organizations that take compliance seriously have discovered a competitive advantage hidden in plain sight.

The Ethics Premium: Data-Driven Proof of Compliance ROI

For the past 15 years, Ethisphere has collected data on its World’s Most Ethical Companies awards, and the results are telling. Companies that earn this designation consistently outperform their peers in stock market performance. Ethisphere refers to this as the “Ethics Premium.” Ethisphere Executive Vice President Erica Salmon Byrne has stated, “In tracking how the stock prices of publicly traded honorees compare to the U.S. Large Cap Index, we found that listed World’s Most Ethical Companies outperformed the large cap sector.”

In 2010, that performance gap was 4.5%. By 2020, the number had surged to 13.5%. Ethical businesses are not only surviving but thriving in competitive markets. The message is simple: investors, customers, and stakeholders place greater value on companies with strong ethical foundations, and the market rewards those companies accordingly.

Academic Research Supports Compliance as a Profit Driver

Beyond market trends, academic research backs up the claim that compliance is a value generator. George Serafeim and Paul M. Healy, in their paper An Analysis of Firms’ Self-Reported Anti-Corruption Efforts, found that companies with robust compliance programs perform better financially in high-risk, corruption-prone countries than those with weaker programs.

One of their key findings was that companies without strong compliance frameworks, despite high sales in these markets, experienced a negative Return on Equity (ROE) of between 24% and 30%. In contrast, companies that invested in compliance infrastructure were better equipped to navigate challenging business environments, sustain long-term growth, and protect shareholder value.

This research reinforces that compliance isn’t just about avoiding fines or regulatory scrutiny—it’s about building a business model that can weather uncertainty and thrive in complex global markets.

Real-World Example: How Compliance Data Drove Profitability

Numbers and research are compelling, but nothing drives the point home like real-world success stories. One such example comes from a company operating in a high-risk FCPA jurisdiction. As part of its compliance initiatives, the company conducted a fraud risk analysis on business development spending related to gifts and entertainment to identify patterns of improper spending and mitigate corruption risks.

Unexpected Findings and a New Compliance Strategy

Without prior approval, the company had a strict $75.00 cap on gifts and entertainment spending. The analysis examined traditional fraud indicators, such as:

  • Split receipts are designed to circumvent the spending limit.
  • Transactions clustered just below the approval threshold.
  • Aggregate spending on individual government officials by multiple salespeople.

However, the results yielded an unexpected insight: spending patterns revealed two distinct thresholds:

  • Data Point A: The minimum spend required to close a deal successfully.
  • Data Point Z: A limit beyond which no additional spending would influence a sale.

Armed with this insight, the company implemented a new policy. Sales teams were required to meet the threshold of Data Point A but were prohibited from exceeding Data Point Z. This simple compliance-driven adjustment had a massive impact:

  1. Immediate Cost Savings: Sales teams stopped wasting money on futile attempts to win business past a certain spending level.
  2. Operational Efficiency Gains: By recognizing when a sale was unlikely to close, sales professionals could pivot more quickly, reducing the overall sales cycle time and improving productivity.

The result? The company eliminated unnecessary expenses and increased overall business unit profitability—all thanks to insights derived from a compliance analysis.

Compliance as a Business Efficiency Tool

This case study is the perfect example of how compliance, when approached strategically, can improve efficiency and profitability. The same principles can be applied across other business functions:

  • Quote-to-Cash (QTC) Sales Cycle: Compliance insights can optimize contract approvals and improve revenue recognition.
  • Procure-to-Pay (P2P) Procurement Cycle: Compliance controls can prevent fraud and enhance supplier negotiation strategies.
  • Third-Party Risk Management: Effective compliance due diligence can reduce supply chain disruptions and improve vendor relationships.

When compliance is embedded within key business processes, it ceases to be a regulatory checkbox and instead becomes a powerful tool for operational excellence.

Reframing the Compliance Conversation: From Cost Center to Profit Generator

Compliance has been considered an overhead expense for years—necessary but not necessarily value-generating. The data, research, and case studies tell a different story. Compliance is not just about avoiding legal trouble; it’s about making smarter business decisions that enhance long-term sustainability.

To reframe the conversation, compliance professionals should:

  1. Leverage Data: Use metrics and research to quantify the financial benefits of ethical business practices.
  2. Tell Compelling Stories: Highlight real-world examples of how compliance has improved profitability and efficiency.
  3. Engage Business Leaders: Collaborate with finance, operations, and sales teams to position compliance as a business enabler rather than a regulatory burden.

The Bottom Line

Ethical companies perform better. Research proves it, and real-world success stories validate it. Businesses that invest in compliance don’t just protect themselves from regulatory risk—they position themselves for sustained profitability and competitive advantage.

It is time for compliance leaders to own this narrative. Compliance is not simply about avoiding penalties; it’s a strategic asset that drives business success. The next time you’re asked to justify your compliance budget, do not just talk about risk; talk about ROI. In today’s world, ethics and profitability go hand in hand.

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Sunday Book Review

Sunday Book Review: February 16, 2025 The Books on AI Edition

In the Sunday Book Review, Tom Fox considers books that would interest the compliance professional, the business executive, or anyone who might be curious. These could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. Today, we have a five-book look at the top books on AI for 2025.

  1. Artificial Intelligence: A Modern Approach by Stuart Russell and Peter Norvig
  2. The Singularity Is Nearer: When We Merge with AI by Ray Kurzweil
  3. The Alignment Problem: Machine Learning and Human Values by Brian Christian
  4. Supremacy: AI, ChatGPT, and the Race that Will Change the World by Parmy Olson
  5. Nexus: A Brief History of Information Networks from the Stone Age to AI by Yuval Harari

Resources:

The Best Books on AI in 2025. In FiveBooks.com

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending February 15, 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 professional and the compliance stories you need to know to end your busy week. Sit back, and in 10 minutes, hear the stories every compliance professional should know 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.

  • SEC looks to muzzle shareholders. (WSJ)
  • Was Shell scammed on oil cleanup? (BBC)
  • Acting US Attorney for SDNY quits over Trump interference. (NYT)
  • CFIUS enforcement is likely to continue under Trump. (Reuters)
  • US drops again on TI-CPI. (WaPo)
  • Mike Madigan was found guilty. (Law360) sub req’d
  • A green light for corruption. (FT)
  • CFPB ordered all work to be stopped ‘immediately’. (NYT)
  • Musk is now making referrals to the US Attorney. (Reuters)
  • McKinsey asks if China is too risky. (Bloomberg)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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

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Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: Week Ending February 15, 2025

Welcome to the Kerrville Weekly News Roundup. Each week, veteran podcaster Tom Fox and his colleagues Andrew Gay and Gilbert Paiz get together to go over a couple of their favorite stories from the past week from Kerrville and the greater Hill Country. Sit back, enjoy a cup of morning coffee and listen in to get a wrap up of the Kerrville Weekly News. We each consider two of our favorite stories and talk about the upcoming weekend’s events which will enjoy or participate in this weekend.

In this episode, Andrew, Tom and Gil returns to take a look at some of the stories which caught their attention over the past week.

Stories Include

  • Bi-County 391 Commission Approved
  • Immigration Policy Protests in Kerrville
  • KPSF Fundraiser
  • Hotel Tax for Kerr County
  • Sherlock Holmes-Mare of the Night Kerrville Premier

Resources

Tom Fox on LinkedIn

Gilbert Paiz on LinkedIn

Andrew Gay on LinkedIn

Texas Hill Country Podcast Network

The Lead

Kerrville Daily Times

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Compliance Tip of the Day

Compliance Tip of the Day – CCM is Essential for 2025 Risk Management

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 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 review Continuous Controls Monitoring (CCM), a requirement for the 2025 risk management professional.

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Career Can D0

Future-Proof Your Career with Clare Brown

What if landing your dream job wasn’t just about earning a degree, but about mastering the modern job search from day one? On this episode of Career Can Do, host, Mary Ann Faremouth, speaks with Clare Brown, a passionate career and job placement services professional at Houston Community College (HCC), about how students can gain a competitive edge in today’s ever-evolving workforce.

Clare shares how HCC’s Career Services team meets students where they are, offering personalized guidance through in-person advising, digital tools like Career Hub, classroom visits, and peer-driven outreach. She stresses that career success isn’t just about academic achievement—it’s about translating education into opportunity. Too often, graduates emerge with theoretical knowledge but struggle with the real-world application of landing a job.

Clare explains that the hiring landscape has changed post-COVID, shifting from self-promotion to proving value—what can you do for an employer? By preparing students early, HCC gives them a critical advantage over those who wait until graduation to figure it all out. Clare passionately describes career services as the ultimate report card of a college. Students may love their classes and professors, but if they walk away without career prospects, they haven’t truly gained what they need. Helping students secure meaningful employment isn’t just a service—it’s a responsibility.

The impact goes beyond recent graduates, as HCC also supports professionals over 55 looking to re-enter the workforce and offers new bachelor’s degree programs to keep up with Houston’s job market demands. Clare’s biggest piece of advice for 2025? Don’t wait. The moment you step onto campus—or even before—engage with career services. The earlier you start, the stronger your chances of success.

Resources:

Clare Brown on Houston Community College | LinkedIn

Mary Ann Faremouth on the Web I X (Twitter)

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12 O’Clock High-a podcast on business leadership

12 O’Clock High, a podcast on business leadership – Leadership Insights from ‘All Quiet on the Western Front’

12 O’Clock High, an award-winning podcast on business leadership, brings together stories from history, the arts, sports and movies, research, and current events to consider leadership lessons. Tom and Richard Lummis return with their fan-favorite series on leadership lessons from Oscar-winning Best Picture movies. Today, we look at leadership lessons from ‘All Quiet on the Western Front.’

Their discussion centers on the graphic depictions of war and how they provide insights into extreme leadership, adaptability, and the disconnect between officers and soldiers. They explore the themes of teamwork and human resilience demonstrated by the characters, especially in challenging situations. A poignant exploration of emotional intelligence and empathy in high-stress environments is also examined, relating these themes to the business world and modern leadership challenges. Join Richard and Tom as they reflect on how these lessons from a nearly century-old text are still relevant today in navigating uncertainty and building resilient frameworks in corporate compliance.

Key highlights:

  • Overview of ‘All Quiet on the Western Front’
  • Themes of War and Leadership
  • Modern Reflections on Military Lessons
  • Emotional Intelligence and Empathy in War
  • Resilience and Decision Making
  • The Role of Data in Leadership

Resources:

All Quiet on the Western Front and Everyday Leadership

Employer Branding Lessons from All Quiet on the Western Front

All Quiet on the Western Front

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