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Word of the Week

Word of the Week with Kenneth O’Neal – Action

Each week, Kenneth O’Neal discusses a word that describes a principle or value of the Qualities of Success. We suggest you use the Word of The Week in your thoughts, deeds, and actions. You might 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 – Action.

In this week’s episode, Kenneth discusses the significance of Action as the word of the week. The discussion emphasizes action not as a sequence of steps but as a crucial mindset that bridges the gap between our current state and our aspirations. Action propels us forward through small, incremental steps or significant leaps, breaking through fear and building momentum. We explore the word’s origins, tracing its historical context back to the statutes of the realm in the 1300s. Adopting an action-oriented mindset and incorporating small actions into daily routines, like making your bed, can significantly enhance personal development and productivity.

Key highlights:

  • Defining Action and Its Importance
  • Taking the First Step
  • The Root of Action

Resources:

KRONEAL Consulting

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Everything Compliance - Shout Outs and Rants

Shout Outs and Rants: Episode 148, The Welcome to Trumps’ First Week Edition

Welcome to this Edition of Everything Compliance, Shout Outs, and Rants. This episode features the truncated triplet of Matt Kelly, Tom Fox, and Karen Moore. They all look at various issues for compliance professionals under the incoming Administration.

  • Karen Moore rants about the sportsmanship for those at the Australian Open who booed Novak Djokovic for having the temerity to become injured and forced to withdraw from his match but shouts out to the Bill Mafia who supported Ravens Tight End Mark Andrews after his dropped touchdown pass.
  • Matt Kelly rants about the Trump Administration’s inane action in trying to invalidate the Constitution and shouts out Senior U.S. District Judge John C. Coughenour for putting a TRO in place for Trump’s alleged Order over-ruling the 14th Amendment on birthright citizenship.
  • Tom Fox shouts out to Jackie Smith, who presaged Mark Andrews by 26 years by dropping a wide-open touchdown pass from Roger Staubach in the 1979 Super Bowl, and to Houston Astro Billy Wagner for his election into the MLB Hall of Fame.

The members of the Everything Compliance are:

Tom Fox, the Voice of Compliance, is the host, producer, and sometimes panelist of Everything Compliance. He can be reached at tfox@tfoxlaw.com. The award-winning Everything Compliance is part of the Compliance Podcast Network.

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

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Innovation in Compliance

Innovation in Compliance – Sam Silverstein on the Fractional Chief Culture Officer

Innovation comes in many areas, and compliance professionals need to be ready for it and 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 is joined by Sam Silverstein from the Accountability Institute to discuss his new service offering, the Fractional Chief Culture Officer.

Sam elaborates on the essential role of a Chief Culture Officer who collaborates with the CEO to establish a culture by design rather than by default. This service allows organizations of all sizes, from those with 24,000 employees to those with just 26, to benefit from their extensive expertise in developing and maintaining a high-performance culture. Sam emphasizes the importance of leadership in driving culture and shares how a fractional chief culture officer can provide the necessary support and tools to ensure that the organization’s values and culture are consistently upheld across all levels. The episode delves into the practical aspects of working with different sizes of organizations, the importance of continuous cultural assessment, and the role of leadership in fostering a sustainable, high-performance culture.

Key highlights:

  • Introducing the Fractional Chief Culture Officer
  • Defining the Role and Importance of a Chief Culture Officer
  • The Continuous Nature of Culture Management
  • Tailoring Services to Client Needs

Resources:

The Accountability Institute

Sam Silverstein

Tom Fox

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Daily Compliance News

Daily Compliance News: January 28, 2025, The TikTok Test 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:

  • TD Bank gets a new Global Head of Financial Crime Risk Management. (WSJ)
  • TikTok test for corporate America. (FT)
  • Would the SEC-CFTC merger be a win for DOGE? (Bloomberg)
  • AI’s role in compliance training. (TechRadar)

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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Blog

AI and Compliance Training

AI-driven training tools are transforming how organizations deliver compliance programs. By offering personalized, interactive, and role-specific training at scale, AI eliminates many cost and logistical barriers that have historically made tailored training challenging. This evolution improves engagement and reduces compliance risks by equipping employees with relevant, actionable knowledge. Today, I want to explore how AI reshapes compliance training, supplemented with real-world examples of companies leading the charge.

Personalization at Scale

AI analyzes vast amounts of data, an employee’s role, learning history, and performance metrics to create tailored training experiences. This ensures that the content is directly relevant to each employee’s responsibilities. For example, a sales team focusing on international transactions might focus on anti-bribery and corruption rules under the FCPA. A procurement team could receive training on vendor due diligence, export control and sanctions, and conflict-of-interest disclosures. Conversely, a finance staff member might dive into anti-money laundering (AML) and financial controls.

You can integrate AI into your global compliance training programs to tailor content to employees’ roles. Through machine learning, your system can deliver specific modules to individuals, ensuring that high-risk roles receive advanced training while others get streamlined, relevant content. The result will be better alignment between training content and operational realities, boosting engagement and effectiveness.

Just-in-Time Learning

AI enables “just-in-time” learning, delivering content at the precise moment it’s needed. For example, an employee preparing to interact with a foreign government official might receive a refresher module on anti-corruption policies before the meeting. Similarly, an employee about to onboard a vendor might receive training on due diligence best practices. This approach effectively ensures that employees apply their knowledge in real-world scenarios when it matters most. It also minimizes the “forgetting curve” by delivering training in digestible chunks that reinforce memory retention.

This means you can use AI to deliver microlearning modules through your internal compliance training platform. Employees receive targeted reminders about data privacy regulations when working on projects involving personal data, ensuring compliance is seamlessly integrated into daily workflows.

Enhanced Engagement Through Gamification 

AI makes compliance training engaging by incorporating gamified elements like quizzes, leaderboards, and decision-making simulations. These interactive features transform mundane lessons into enjoyable experiences, boosting motivation and retention. Imagine employees participating in a simulated bribery scenario, navigating ethical dilemmas in real time. Such immersive experiences teach policies and foster critical thinking and decision-making skills.

For example, PwC’s Game of Threats™ is a digital game that simulates the speed and complexity of a real-world cyber breach. It is designed to help executives “understand the steps they can take to protect their companies. The game environment creates a realistic experience where both sides, the company and the attacker, are required to make quick, high-impact decisions with minimal information.” You can “coach players through realistic scenarios with different types of threat actors and their preferred methodologies and explain what they can do to better prevent, detect, and respond to an attack.”

Continuous Improvement

AI-powered platforms don’t just deliver training; they learn and adapt. These systems analyze performance metrics, such as quiz scores and engagement rates, to identify areas where employees struggle. Based on this data, the platform refines its content, ensuring that training evolves alongside organizational needs and regulatory changes.

One company implemented AI-driven tools for compliance training that adapt based on user feedback and performance data. If employees consistently fail a particular module, the AI identifies gaps and adjusts the content to address misunderstandings more effectively.

Cost-Effective Solutions for Large Organizations

Scaling traditional training methods across a large global workforce is challenging and expensive. AI simplifies this by automating the customization process, ensuring consistent quality across teams and geographies. It also reduces costs associated with in-person training sessions and printed materials—one large multinational leveraged AI to implement a scalable compliance training platform for its over 150,000 employees. By automating the delivery of role-specific training modules and offering multi-language support, Unilever significantly reduced training costs while maintaining high levels of engagement and effectiveness.

Overcoming Barriers to AI Adoption in Compliance Training

Unfortunately, despite its obvious benefits, some organizations hesitate to adopt AI-driven compliance training due to perceived challenges. Some of these challenges include one or more of the following concerns: The Cost Concern is where the initial investment in AI tools seems way too high. This is even where the long-term savings, through improved training efficiency and reduced compliance risks, far outweigh the upfront expenses. Another concern is around the Technological Complexity. Partnering with experienced vendors or consultants can simplify the implementation process, ensuring seamless integration with existing systems. Finally, there is the ever-present Cultural Resistance. Employees may resist AI-driven training for fear of surveillance or skepticism about its effectiveness. Clear communication about how AI enhances training rather than replacing human oversight can help alleviate these concerns.

The Future of Compliance Training: AI as a Strategic Advantage

AI-driven compliance training is more than just a technological upgrade; it is a strategic advantage that organizations can use in various ways. It can mitigate compliance risks by delivering tailored, engaging, and timely training. AI reduces the likelihood of compliance violations and associated penalties. It can build and foster trust between compliance and your customer base, which is corporate employees. Employees who feel supported with relevant, engaging training are more likely to embrace compliance as part of their workplace culture. Finally, it will allow you to stay ahead of the compliance curve in training and potentially the Department of Justice (DOJ). AI ensures training evolves alongside regulatory changes, keeping organizations proactive rather than reactive.

The message is clear: Investing in AI-driven compliance training is not just about ticking boxes; it is rather about building a resilient, ethical organization that thrives in today’s complex regulatory environment. If your company has not yet embraced the AI revolution in compliance training, now is the time to explore the possibilities. With the right tools and a commitment to meaningful employee engagement, you can transform compliance from a checkbox exercise into a powerful driver of business success.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 27 – The Compliance Function in an Organization

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.

On Day 27, we explore the growing importance and responsibilities of the compliance function within corporations, emphasizing the need for adequate staffing, resources, and independence. The 2020 FCPA Resource Guide outlines key factors that the DOJ considers indicative of an effective compliance program, including the quality of personnel, authority, compensation, and reporting structure. We delve into the necessity of properly funding compliance initiatives and ensuring the organization empowers and sufficiently supports compliance professionals. The updated Corporate Enforcement Policy emphasizes the prevention of retaliation against compliance investigators and the need for a robust structure supporting the compliance program. We conclude with three key takeaways for enhancing compliance functions: evaluating their treatment in the budget process, ensuring management respects compliance decisions, and considering the implications of outsourced compliance services.

Key highlights:

  • DOJ’s Expectations for Compliance Programs
  • Funding and Resources for Compliance
  • Compliance Program Structure and Authority

Resources:

Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast.

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The Ethics Experts

Episode 192 – Greg Shultz

In this episode of The Ethics Experts, Nick welcomes Greg Shultz.

Greg Shultz, Founder of Conformitise, is a global compliance and risk executive with over 24 years of experience, including 11 years living and working across the Asia Pacific region. His career has been defined by roles at leading financial institutions, including Morgan Stanley and BlackRock, where he designed and executed strategic compliance programs and spearheaded technology-driven initiatives to mitigate global risks and enhance regulatory frameworks.

Prior to financial services, Greg was at the United Nations, where he served on the investigation committee led by former Federal Reserve Chairman Paul Volcker during the Iraqi Oil-for-Food Programme Investigation. In this role, Greg played a pivotal part in uncovering corruption and fund misappropriation in one of the most complex humanitarian operations in history. This experience solidified his focus on fostering transparency, strengthening compliance, and managing strategic risk on a global scale.

Greg’s LinkedIn

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Corruption, Crime and Compliance

2024 FCPA Enforcement and Compliance Review

Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025? Will the push for innovation in corporate compliance programs be enough to maintain momentum, especially with emerging technologies like artificial intelligence? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives deep into the FCPA enforcement landscape of 2024, outlining key cases, changes in DOJ policies, and the evolving role of compliance programs. He highlights the significant rise in penalties and individual criminal prosecutions and the continuation of major corporate settlements such as Raytheon, Trafigura, Gunvor, and SAP. The episode also explores the DOJ’s new whistleblower program and its continued push for companies to enhance their compliance frameworks.

You’ll hear him discuss:

  • Key FCPA enforcement matters in 2024, including the Raytheon, Trafigura, Gunvor, and SAP cases.
  • The shift in DOJ’s approach, where individual prosecutions now play a larger role than ever before.
  • The rise in penalties: 2024 saw a significant jump, with a total of $1.7 billion in fines.
  • The return of travel, hospitality, and gifts as common bribery techniques, despite increased focus on compliance.
  • DOJ’s major industry sweeps, particularly targeting the energy commodity trading industry.
  • The emergence of new compliance challenges with a focus on artificial intelligence and emerging technologies in corporate settings.
  • The controversial SAP settlement and the DOJ’s approach to a lack of voluntary disclosure.
  • The impact of mergers and acquisitions on compliance processes and the integration of acquired companies.
  • DOJ’s new whistleblower program is designed to incentivize individuals to report misconduct.
  • How companies should approach merger and acquisition integration to ensure compliance and prevent risks.

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Riskology

Riskology by Infortal™: Episode 40 – International Expansion: Conquering Risk with Special Guest Frank Lavin

For the milestone 40th episode of Riskology by Infortal™ co-hosts Dr. Ian Oxnevad and Chris Mason are thrilled to welcome Frank Lavin, a Visiting Fellow at Stanford University’s Hoover Institution and a leading expert in international commerce.

This episode covers the challenges companies face when taking their business to new markets overseas.

Featured Guest: Frank Lavin

Frank Lavin works on Asia and trade policy as a Visiting Fellow at the Hoover Institution.

In the Reagan Administration, Lavin served on the National Security Council and the White House staff in addition to assignments in the State Department.

Lavin later served in the Bush (41) and Bush (43) administrations, in the latter as Ambassador to Singapore and Under Secretary for International Trade at the Department of Commerce.

In the private sector, Lavin served in senior finance positions in Hong Kong and Singapore with Bank of America and Citibank.

He is a columnist for Forbes.com and the author of several books, including “Inside the Reagan White House,” “The Smart Business Guide to China E-Commerce,” “Export Now,” and “Home Front to Battlefront.”

International Business Expansion

In a rapidly evolving global landscape, businesses aiming to expand internationally must adopt strategies that balance business opportunity with sound risk management.

Partnerships are also key to gaining a foothold in new markets, and utilizing local service providers can help bridge the cultural gap inherent in doing business in a new jurisdiction.

These partnerships can also help navigate the local business environment and mitigate risks associated with unfamiliar regulatory landscapes. Gaining insights based on local market intelligence, especially in regions with geopolitical fluctuations, is critical to your success.

It is important, however, to make sure you gain a deep understanding of who you are doing business with in new markets. Your new partners can make or break your reputation both at home and abroad. This requires conducting deep dive due diligence on key new partners to avoid any hidden risks.

Geopolitical Risk Considerations

In 2025, geopolitics will present an ever-expanding set of risk factors that require careful analysis and consideration before taking a leap into new markets.

Importantly, there are a lot of governmental and private sector resources available to help with the strategic planning process. Entities like the U.S. Commercial Service and state-level trade offices provide vital insights and connections that can facilitate market entry. Further, local banking and legal contacts can prove beneficial.

Finally, you should also consider conducting a geopolitical risk assessment of the planned expansion based on local, boots-on-the-ground intelligence.

By leveraging geopolitical risk analysis and the right market intelligence, companies can attain a competitive edge while minimizing risks associated with international expansion.

Key Takeaways:

  • Adopt a Light Footprint Strategy for International Expansion
    Instead of replicating your US operations in a new market, you should consider starting with scaled-down capital investment by outsourcing services such as logistics and distribution.
  • Utilize All Available Resources and Networks
    To facilitate international business expansion, leverage all available resources, including government agencies and private sector service providers. It may seem straightforward, but understanding the new market conditions before entering will strengthen your operating model and help you avoid significant risk.
  • Evaluate New Markets with a Risk-First Mindset
    Rank potential foreign markets in terms of risk when deciding where to expand your business first. You may want to first consider lower-risk market entry points and build from there.

Tune in to the latest episode of Riskology by Infortal™ to gain a deeper understanding of how to approach international business expansion.

 

Resources:

Infortal Worldwide

Email

Frank Lavin on LinkedIn

Dr. Ian Oxnevad on LinkedIn

Chris Mason on LinkedIn

Categories
Daily Compliance News

Daily Compliance News: January 27, 2025, The IG Massacre 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:

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.