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The Ethics Experts

Episode 190 – Tyson Avery

In this episode of The Ethics Experts, Nick welcomes Tyson Avery.

Tyson M. Avery serves as Lucid Motors’ Deputy General Counsel, Ethics and Compliance. He is responsible for leading, developing, and enhancing the global ethics and compliance department of a new, publicly traded luxury EV company. This includes mitigating regulatory risk in areas such as anti-corruption, sanctions, trade, anti-competition, and OEM-specific requirements. He also facilitates and directs a multi-departmental internal investigation program and leads the company’s third-party due diligence process.

Categories
Adventures in Compliance

The Case-Book of Sherlock Holmes – Business Ethics Lessons in ‘The Adventure of the Blanched Soldier

In this new season of Adventures in Compliance, host Tom Fox delves 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 another lesser-known of all the Holmes stories, The Adventure of the Blanched Soldier.

As part of ‘The Casebook of Sherlock Holmes,’ this episode examines business ethics and the ethical leadership of a corporate compliance function. The story offers a unique, Holmes-centric narrative that provides compelling lessons for compliance professionals and business leaders. This story, told from Holmes’ perspective, delves into themes of trust, transparency, and the consequences of concealing the truth—principles central to ethical business practices.

The Adventure of the Blanched Soldier reminds us that secrecy, fear, and miscommunication often compound ethical dilemmas. For compliance professionals, the story serves as a case study of the importance of transparency, compassion, and thorough investigation. By applying these lessons, businesses can build a culture of trust and accountability that stands the test of scrutiny—whether from Holmes or the Department of Justice.

Highlights include:

  • Introduction to The Adventure of the Blanched Soldier
  • Transparency in Compliance
  • Institutional Justice and Institutional Fairness
  • A Second Set of Eyes
  • Rebuilding Trust

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

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

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Categories
Riskology

Riskology by Infortal™: Podcast Episode 39 – 2025 Top 10 Geopolitical Risks

In 2025, the geopolitical game is changing.

After over half the world voted in elections in 2024, we’re on the brink of significant regulatory shifts impacting businesses globally.

As we look at 2025, different administrations will clash, shaping a competitive landscape of rules and norms. This means compliance teams will be in high gear as companies must adapt to new regulatory demands.

In the first Riskology episode of 2025, hosts Dr. Ian Oxnevad and Chris Mason break down the top 10 geopolitical risks for companies to consider in 2025.

  1. Global Conflicts – Understanding the overarching impact of global conflict on every aspect of business, from tariffs to supply chains.
  2. U.S.-China Trade Wars – Analyzing the implications of trade tensions on global markets and supply chains.
  3. Supply Chain Risk – Examining the evolving nature of supply chains amid geopolitical shifts and conflict.
  4. Social Unrest and Terrorism – Evaluating the business implications of social movements and terrorism worldwide.
  5. Cybersecurity Threats – Discussing the rise of state-backed cyber threats and the importance of robust cybersecurity measures.
  6. Economic Espionage – Exploring the growing threat of economic espionage, highlighting the need for vigilance.
  7. Shifting Regulatory Environment – Predicting the regulatory changes under new administrations worldwide and their effects on businesses.
  8. AI Governance – Considering the various directions AI governance may take amid the international race to lead in AI technologies.
  9. Environmental Risk – Highlighting the geopolitical impacts of environmental events on business operations and supply chains.
  10. Global Migration – Discussing the complexities and economic impacts of migration trends influenced by global conflicts.

In 2025, global conflicts will not just be featured in the headlines; they will impact us all, shaping migration patterns, market performance, and corporate strategies.

It’s crucial to conduct contingency planning specific to your industry. Riskology by Infortal™ host Chris Mason notes that “…contingency planning for the larger financial institutions…involves stress testing, looking at things like liquidity and what your investment portfolio looks like.” Contingency plans provide alternative strategies that prepare your business for potential disruptions caused by geopolitical risks, ensuring business continuity.

Companies should also focus on training their teams, especially in cybersecurity and economic espionage. Ensuring you provide training to your team, particularly at the board level, will strengthen your firm’s ability to deal with emerging threats. Training also aids in quicker response times and empowers employees to identify and react to threats effectively.

Want to stay ahead of the geopolitical risk curve? Check out Riskology by Infortal™ Episode 39!

Resources:

Infortal Worldwide

Email

Dr. Ian Oxnevad on LinkedIn

Chris Mason on LinkedIn

Categories
Corruption, Crime and Compliance

Deep Dive into AAR FCPA Enforcement Action

How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant? In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary tale of bribery, insider deals, and compliance failures in high-risk sectors. The DOJ and the Securities and Exchange Commission (SEC) closed 2024 with a major coordinated settlement with AAR Corporation, a provider of aviation products and services. The case involved criminal and civil FCPA charges related to Nepal and South Africa bribery schemes. Deepak Sharma, the CEO of an AAR subsidiary, orchestrated the schemes, securing insider information and paying bribes to government officials to win lucrative contracts. Despite AAR’s late self-reporting, the DOJ credited the company for its cooperation and remediation efforts. The case highlights ongoing corruption risks in the aviation industry, especially where state-owned enterprises and third-party agents are involved.

You’ll hear him discuss:

  • The details of the Illinois-based provider of aviation products, AAR Corporation, FCPA settlement with the DOJ and SEC.
  • How Deepak Sharma orchestrated bribery schemes in Nepal and South Africa.
  • Under the separate civil resolution with Deepak Sharma, Sharma agreed to pay a disgorgement of $130,835 plus prejudgment interest of $53,762.
  • The role of third-party agents in facilitating corrupt practices.
  • Julian Aires, a former third-party agent of AAR, pleaded guilty in the District of Columbia on July 15, 2024,, to a conspiracy to violate the FCPA for his role in the South Africa scheme.
  • Why insider information from government officials is a “kiss of death” in compliance.
  • How bribes were disguised through sham invoices and shell companies.
  • The importance of robust compliance programs in high-risk industries like aviation.
  • Red flags to watch for in industries dealing with state-owned enterprises.
  • How the DOJ and SEC weigh cooperation and remediation in enforcement actions.
  • Key takeaways for compliance professionals from the AAR case.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
FCPA Compliance Report

FCPA Compliance Report – Strategic ROI: Navigating Export Controls and Compliance

Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes back Brent Carlson and Mike Huneke to discuss a crucial topic in corporate compliance: the return on investment (ROI) in export controls compliance.

This pod reviews the challenges compliance professionals face in articulating the value proposition for investments in compliance programs. Brent and Mike highlight the misconceptions about compliance being merely a cost center and explore various ways to demonstrate its tangible benefits to executive teams and boards. The discussion also covers the impact of recent regulatory changes and geopolitical tensions and how companies can proactively address these shifts to ensure robust compliance and leverage new opportunities. By looking at past enforcement actions and drawing parallels with the evolution of the FCPA, the episode provides listeners with critical insights into the practical steps for enhancing compliance programs and the importance of staying ahead of regulatory expectations in a rapidly changing global trade environment.

Key highlights:

  • Setting the Stage for Compliance ROI
  • Challenges in Export Controls Compliance
  • Geopolitical Influences on Export Controls
  • Comparing Export Controls to FCPA
  • National Security and Economic Security
  • Solutions and Strategies for Compliance

Resources:

Hughes Hubbard & Reed website

Brent Carlson on Linkedin

Mike Huneke on LinkedIn

A Fresh Look at US Export Controls and Sanctions

Tom Fox

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

Categories
Daily Compliance News

Daily Compliance News: January 13, 2025 – The End of Western Civilization 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:

  • LiquidNet to pay a $5MM fine. (WSJ)
  • TikTok warns of dire consequences if it has to follow the law. (Reuters)
  • Is HR your friend? (NYT)
  • JPMorgan shuts off the comment line. (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.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 13 – Policies and Procedures

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this episode, we review the importance of having well-crafted compliance policies and procedures as the foundation of a robust compliance program. As highlighted by the 2024 ECCP and 2020 FCPA Resource Guide, such policies and procedures are crucial for addressing and mitigating risks identified during a company’s risk assessment. Regulators emphasize having articulated anti-bribery and anti-corruption policies regularly reviewed and updated to reflect evolving risks. We discuss the five general elements of a compliance policy and underscore the need for consistent implementation to maintain the credibility and effectiveness of the compliance program. Key takeaways include the necessity of written policies, expectations from the DOJ and SEC, and the critical role of institutional fairness.

Key highlights:

  • Importance of Compliance Policies
  • Key Elements of Compliance Policies
  • Assessment and Evolution of Policies

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 12 – The Importance and Construction of a Corporate Code of Conduct

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

This episode explores the critical value and construction of a corporate Code of Conduct, explaining its evolution from a legalistic document to a cornerstone of compliance programs. The discussion includes an analysis of the 2016 SEC Enforcement Action against United Airlines, highlighting how violations of the Code of Conduct can lead to severe consequences, including substantial penalties and executive resignations. Key takeaways emphasize that a Code of Conduct should be tailored to a company’s specific culture and industry, must be accessible to all employees, and needs to be regularly updated and documented to ensure its effectiveness. Tune in to learn why a robust Code of Conduct is foundational for any compliance program.

Key highlights:

  • Introduction to Code of Conduct
  • Regulatory Expectations and Guidelines
  • Crafting an Effective Code of Conduct

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
Sunday Book Review

Sunday Book Review: January 12, 2025 – The Top Business Books Coming in 2025 Edition

In the Sunday Book Review, Tom Fox considers books that interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. This month of January, we will review the top books on some key areas of interest for compliance professionals. This week, four upcoming books in 2025 for business leaders.

 

  1. How to Dao by Kevin Owocki and Puncar
  2. The Power of Purpose, 4th edition by Richard Leider and David Shapiro
  3. The Resilient Leader by Brian Molitor
  4. House of Huawei by Eva Dou

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

Categories
Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: January 11, 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 we will enjoy or participate in this weekend.

In this episode, Tom, Gilbert, and Andrew return for their first episode of the new year and examine some of the things that caught their attention over the past week.

Stories include:

  • End of Bridget’s Basket
  • Entertainment Mart moves to the Mall
  • Frost Bank is coming to Kerrville
  • Development near Comanche Trace
  • CJ Goodwyn and Mare of the Night

Resources:

Tom Fox on LinkedIn

Gilbert Paiz on LinkedIn

Andrew Gay on LinkedIn

Texas Hill Country Podcast Network

The Lead

Kerrville Daily Times