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Compliance Into the Weeds

Compliance into the Weeds – Autonomous AI Whistleblowing Misconduct

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly consider what happens when AI turns whistleblower.

The advent of AI technologies, such as Claude Opus 4, has sparked debates over the potential for AI systems to autonomously report misconduct, presenting new ethical and operational challenges within AI governance. Tom Fox views AI whistleblowing with caution, questioning the feasibility of implementing effective governance rules and the complexities involved in distinguishing between AI-generated reports and those of human whistleblowers. His concerns are shaped by the legal and ethical implications of AI’s autonomous actions, highlighting a pressing need for clearer regulations. Similarly, Matt Kelly is concerned about the ethical nuances, emphasizing the difficulty AI might face in understanding corporate ethics and compliance culture without human oversight, and underscores the urgent need for regulatory frameworks to keep pace with the advancements in AI. Fox and Kelly’s perspectives converge on the necessity for robust oversight mechanisms and strategic planning to manage the compliance challenges posed by AI in whistleblowing scenarios.

Key highlights:

  • Autonomous AI Reporting Misconduct to Authorities
  • Navigating AI Ethics for Regulatory Compliance
  • Distinguishing AI Reporting in Whistleblower Cases
  • Navigating AI Challenges in Compliance Programs

Resources:

Radical Compliance

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A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

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Daily Compliance News

Daily Compliance News: June 4, 2025, The Climate Disaster Management 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 of which are relevant to the compliance professional.

Top stories include:

  • Tesla tells employees that poor culture is their responsibility. (WSJ)
  • More spy claims in HR SaaS battle. (FT)
  • AI and Thought Leadership. (FT)
  • What is climate disaster management?  (Bloomberg)
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Blog

The AI Revolution in Regulatory Change Management

Recently, I had the opportunity to visit with John Byrne, the CEO at Corlytics. You can listen to the podcast here. Every compliance professional understands that regulatory change management is one of the most complex, labor-intensive, and time-consuming tasks within any organization. Regulations emerge continuously, each bringing extensive new obligations that ripple across multiple business units, policies, and control frameworks. Compliance teams historically faced daunting timelines, sometimes taking an entire year to fully analyze, interpret, and implement changes in business operations. However, innovations in technology are dramatically reshaping this landscape. Imagine compressing twelve months of arduous regulatory adjustments into mere moments. This is no longer just aspirational thinking; it is reality.

In today’s post, we’ll examine the traditional complexities around regulatory change management, how cutting-edge technology is radically streamlining this process, and highlight five critical lessons compliance professionals can leverage to optimize their organization’s responsiveness to regulatory developments.

Lesson 1: Understand the Traditional Challenges of Regulatory Change

Before appreciating modern solutions, it’s crucial to acknowledge historical complexities. Significant regulatory initiatives, such as MiFID II and Dodd-Frank, have dramatically reshaped the compliance landscape, demanding extensive recalibration. For example, MiFID II significantly impacted the Financial Conduct Authority’s (FCA) handbook, altering roughly 40% of its content. Such sweeping regulatory changes ripple throughout an organization, affecting various business functions, including operations, risk management, and compliance.

Traditionally, each of these changes required meticulous manual analysis, dissemination across multiple departments, and comprehensive impact assessments. Compliance teams had to painstakingly map how regulatory shifts affected their business model, risk frameworks, internal controls, and policies, typically involving months of collaboration, interpretation, and documentation.

Lesson 2: The Importance of Cross-Functional Collaboration

Managing significant regulatory changes is not a solitary compliance exercise. It demands deep cross-functional collaboration between compliance, risk, legal, operations, and business leaders. Historically, compliance teams coordinated painstakingly with each business unit to understand regulatory impacts and necessary adjustments.

This cross-functional coordination ensured a comprehensive understanding of the business and a successful implementation. Yet, manually driven communication meant the process was slow and prone to misunderstandings. A robust, streamlined mechanism to align diverse departments swiftly is now not only beneficial but essential. Compliance professionals must embrace strategies and technologies that facilitate rapid, precise, and accurate cross-departmental collaboration.

Lesson 3: Assessing Risk—Beyond Just Understanding Changes

It is not sufficient merely to understand regulatory changes; one must also apply them effectively. Compliance teams must rigorously assess how these changes influence organizational risk profiles. Each regulatory adjustment brings new risks or modifies existing ones. Historically, comprehensive risk assessments involved extensive discussions and manual reviews, taking months to identify, classify, and appropriately mitigate emerging threats.

Advanced technology can dramatically accelerate and automate this critical phase. Modern systems enable compliance professionals to model potential regulatory impacts instantaneously, revealing dynamic insights into evolving risk landscapes. Adopting such real-time analytical capabilities significantly enhances compliance teams’ ability to manage emerging threats proactively.

Lesson 4: Implementing and Updating Controls and Policies Efficiently

Once compliance professionals understand the regulatory implications and associated risks, the next challenge is to adjust internal controls and policy frameworks accordingly. Typically, senior executives across risk, compliance, and legal functions painstakingly review, adjust, and approve these critical documents. Implementation, followed by extensive training and communication, added significantly to the process time.

The transition from manual to automated processes is transformative here. Imagine a scenario where changes to policies, procedures, and controls are instantly drafted, reviewed, and documented, allowing senior compliance and risk leaders to validate adjustments swiftly. Such automation dramatically reduces operational disruption, enhances accuracy, and enables compliance professionals to focus strategically rather than getting bogged down in administrative minutiae.

Lesson 5: Leveraging Technology for Real-Time Regulatory Compliance

Perhaps the most groundbreaking shift in regulatory change management is transitioning from manual, slow-moving processes to leveraging AI and automation tools capable of real-time responses. The technology described, for instance, compresses extensive manual processes, such as marking up regulatory documents and determining future obligations, into seconds, thereby enabling rapid adjustments to controls and procedures.

Imagine: within moments of identifying a new regulatory requirement, compliance teams instantly understand the implications across obligations, policies, and internal controls. The immediate efficiency, traceability, and accuracy this provides are profound. It represents a paradigm shift in compliance effectiveness and agility, transforming compliance from a reactive, slow-moving department into a nimble, strategic powerhouse capable of proactively safeguarding organizational integrity and regulatory adherence.

Conclusion: Embracing the Future of Compliance

For compliance professionals, the transformative potential of real-time regulatory change management is immense. The era of manual, drawn-out compliance adjustments is rapidly fading, replaced by swift, technology-driven processes offering unprecedented accuracy, responsiveness, and strategic value.

To remain competitive and compelling, compliance teams must proactively adopt and leverage these technological advancements to stay ahead of the curve. Real-time analytics, dynamic traceability, and instantaneous updates to controls and policies allow compliance professionals to move from reactive gatekeepers to proactive business enablers. Ultimately, organizations adopting these innovative approaches will experience significantly reduced compliance risks, greater operational efficiencies, and enhanced strategic decision-making capabilities.

Compliance leaders must act now by exploring, testing, and deploying technologies that enable rapid and accurate responses to regulatory shifts. Those who succeed will not only dramatically enhance their compliance effectiveness but will solidify their role as indispensable strategic partners within their organizations, capable of guiding businesses confidently through the ever-changing regulatory landscape.

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Upping Your Game

Upping Your Game – Harnessing AI to Revolutionize Third-Party Risk Management

In February, the Trump Administration suspended investigations under and enforcement of the FCPA. Many compliance professionals have since wondered what this will mean for corporate compliance programs going forward. Hui Chen challenged compliance professionals with the statement, “It’s time to up your game.”

This podcast series, sponsored by Ethico and co-hosted by Ethico co-CEO Nick Gallo, aims to meet Hui Chen’s challenge for compliance professionals. We will discuss how compliance professionals can ‘Up Their Game’ by utilizing currently existing Generative AI (GenAI) tools to significantly enhance their compliance programs. As compliance professionals, it is crucial to recognize that this moment is not merely about incremental improvements but about elevating our profession to an entirely new level of effectiveness, efficiency, and organizational value.

In this episode, Tom and Nick delve into the transformative potential of AI in mitigating third-party compliance risks. They discuss the inherent limitations of traditional compliance methods, which are often reactive and manual. The conversation highlights how AI can streamline processes, minimize false positives, and boost efficiency by offering real-time monitoring and data analysis. They also highlight the broader business value of AI, which can expedite onboarding, enhance risk identification, and ultimately drive greater return on investment (ROI). They conclude that the importance of investing in AI training for compliance teams lies in staying ahead of the curve and maximizing the benefits of these emerging technologies.

Key highlights:

  • Challenges in Third-Party Risk Management
  • AI as a Game Changer
  • Types of Third-Party Risks
  • Business Value of AI in Compliance
  • Innovations and Tools in AI
  • Practical Applications and Examples

Resources:

Upping Your Game-How Compliance and Risk Management Move to 2030 and Beyond on Amazon.com

Nick Gallo on LinkedIn

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Tom Fox

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Innovation in Compliance

Innovation in Compliance: Integrating AI in Compliance and Risk Management with Jana Brost

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 Jana Brost, COO at myCOI, the sponsor of this podcast.

They chat about the intersection of compliance, risk management, and AI. Jana discusses her background in high-growth business process outsourcing and data analysis, as well as her journey to joining my company. She explains the concept of Certificates of Insurance (COIs) and their importance in managing risk for companies. The conversation examines how myCOI empowers vendors and owners to manage their insurance requirements more efficiently through the use of AI, highlighting key industry trends and the impact of AI on speed, accuracy, and user experience. Jana also discusses the future of AI in risk management and its potential to enhance employee engagement and foster a positive company culture.

Key highlights:

  • Understanding COIs in Construction
  • Risk Management and Insurance
  • Evolution of COI Management with AI
  • AI’s Impact on Vendors and Owners
  • Customer Expectations and AI
  • Future of AI and Company Culture

Resources:

Jana Brost on LinkedIn

myCOI

Tom Fox

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

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Blog

The Future of Compliance: From Risk Management to Strategic Business Partner

Recently, I had the opportunity to visit with John Byrne, the CEO at Corlytics. You can listen to the podcast here. One of the areas we discussed is that the compliance landscape is experiencing a fundamental shift, moving compliance professionals from traditional gatekeeping roles to strategic leadership positions within their organizations. Historically viewed as mere regulatory enforcers, compliance teams are increasingly recognized as essential partners in managing strategic risks. Recent global disruptions, such as unexpected tariffs and political upheavals that impact anti-corruption enforcement, as well as unprecedented events like the COVID-19 pandemic, underscore the inadequacies of traditional, static compliance frameworks.

These events emphasize a crucial truth: compliance must become agile, proactive, and deeply integrated into core business strategies to effectively anticipate and respond to rapidly evolving risks. The compliance function of tomorrow is not simply reactive; it actively shapes organizational resilience and strategic decision-making. By harnessing advanced technologies like artificial intelligence, compliance professionals can significantly enhance their capacity to identify and manage emerging risks rapidly.

In this transformed role, compliance becomes not just a defensive measure but a strategic asset positioned to enable innovation, accelerate growth, and protect organizational integrity. Embracing this vision is essential if compliance teams are to fully realize their potential as indispensable strategic leaders, securing their organizations against unforeseen challenges and positioning them for sustained success.

Lesson 1: Recognizing Compliance as Strategic Risk Management

Compliance is evolving from a purely regulatory-driven necessity into a dynamic strategic asset. At its core, compliance is a risk management process that involves identifying, assessing, managing, and mitigating risks to ensure organizational stability and effectiveness. Traditionally, this process has been laborious, reactive, and often separated from core business functions. Now, aided by technology such as artificial intelligence (AI), compliance professionals can leverage dynamic traceability and advanced analytics to accelerate risk identification and assessment dramatically.

In this rapidly evolving environment, compliance must take an active leadership role. Rather than passively reacting to regulatory requirements, compliance professionals need to proactively anticipate and manage emerging threats, positioning themselves as forward-thinking strategic advisors who protect and enable business growth.

Lesson 2: No More Black Swans—Every Risk Must Be Anticipated

Historically, compliance teams spent significant resources preparing for rare, highly impactful “black swan” events. However, recent history teaches that events previously considered extraordinary, such as pandemics, economic disruptions, or sudden political shifts, are becoming increasingly commonplace. There are no actual black swan events anymore; instead, there are just unexpected events.

Compliance professionals must recalibrate their mindset and methods, accordingly building agile systems capable of rapid adaptation. Compliance frameworks must be resilient, flexible, and proactive enough to manage uncertainties and unexpected scenarios effectively, even those we have not imagined yet. Rather than planning for specific black swans, compliance teams need adaptive frameworks and advanced scenario-planning capabilities to navigate an uncertain future.

Lesson 3: Embedding Compliance Directly into Core Business Operations

One of the most promising evolutions in compliance is its integration directly into the heart of business operations. Traditionally, compliance and operational functions operated in isolation, often misunderstanding or miscommunicating with one another. Compliance would issue requirements, leaving operational teams struggling to interpret and effectively implement directives.

Future-oriented compliance departments must break down these walls. The ideal structure aligns compliance closely with operational teams, creating shared understanding and cooperation. For instance, onboarding a large corporate client at a tier-one bank typically takes 40 days. Embedding compliance directly into the onboarding process and leveraging real-time compliance monitoring and collaboration could dramatically shorten this timeframe, delivering tangible value to customers and the firm.

Lesson 4: Creating a Learning Compliance Organization

A strategic compliance function doesn’t merely enforce rules; it continuously learns and adapts. It asks key questions: How can we improve outcomes? How can compliance processes create greater value for the business and its clients?

To become genuinely strategic, compliance departments must embrace a culture of continuous improvement. They should leverage advanced technologies, foster cross-functional teamwork, and cultivate an open and collaborative learning culture that continually seeks improvement in processes and outcomes. By shifting towards this learning organization model, compliance can better support business growth, enhance customer satisfaction, and foster a competitive advantage.

Lesson 5: Leveraging ‘What If’ Scenario Planning to Enable Business Innovation

A dynamic compliance function can actively support and accelerate business innovation through sophisticated “what if” scenario analysis. Instead of merely assessing past risks, compliance teams equipped with advanced analytical tools can proactively evaluate risks associated with potential future business decisions.

This capability enables compliance professionals to quickly analyze the implications of entering new markets, launching innovative products, or changing business strategies. Imagine compliance contributing proactively during product development, swiftly identifying regulatory or operational roadblocks. This proactive, strategic role not only prevents future compliance issues but also dramatically accelerates innovation, reduces client pain points, and fosters faster, more confident business decisions.

Compliance as a Critical Strategic Partner

The compliance profession stands at a crossroads, with immense potential to redefine itself as a strategic asset essential to organizations. Compliance professionals possess a unique skill set that enables them to lead dynamic risk management efforts—identifying risks, rapidly deploying mitigation strategies, and facilitating proactive decision-making. By leveraging technologies like AI and cultivating deep integration with operational functions, compliance departments can reposition themselves from gatekeepers to strategic business enablers.

The future of compliance lies in proactive leadership, continuous learning, and deep integration within the organization’s strategic fabric. This evolution not only enhances compliance outcomes but also transforms compliance into a mighty, positive contributor to organizational growth, innovation, and success.

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Compliance and AI

Compliance and AI: Using AI for Data Loss Prevention Systems with Vinay Goel

What is the role of Artificial Intelligence in compliance? What about Machine Learning? Are you using ChatGPT? These questions are just three of the many we will explore in this cutting-edge podcast series, Compliance and AI, hosted by Tom Fox, the award-winning Voice of Compliance. In this episode, Tom is joined by Vinay Goel, co-founder of Wald.ai.

They discuss Goel’s professional background, his journey to founding his company, Wald.ai, and the transformative impact of AI, particularly following the launch of ChatGPT. Goel shares insights into the compliance challenges posed by AI, the importance of secure AI usage, and how businesses can strike a balance between productivity and data protection. They also delve into democratizing workplace data through AI and the importance of privacy and identity protection in AI solutions. Goel offers practical advice for companies seeking to adopt AI responsibly, discussing the future of AI in the business world.

Key highlights:

  • The Inspiration Behind Wald
  • AI and Data Security Challenges
  • Compliance and AI Usage
  • Democratizing Data with AI
  • Future of AI and Compliance

Resources:

Vinay Goel on LinkedIn

Wald.ai

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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.

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Blog

From Compliance to Strategic Risk Management: A Conversation with John Byrne

I recently had an opportunity to sit down with John Byrne, CEO of Corlytics, for a podcast recording. The episode is posted here in my Compliance and AI podcast. Corlytics sponsored the podcast. We had a fascinating conversation about the next steps forward for compliance professionals, exploring tools, insights, and strategies that help us not just react to regulatory changes but proactively embed compliance into the heart of business operations.

Corlytics has recently achieved ISO 42001 certification, a milestone that marks it as a true pioneer in the RegTech space. For those unfamiliar, ISO 42001 establishes rigorous standards for AI model testing, validation, and robust processes that protect against misuse and data vulnerabilities. Byrne emphasized that this certification demonstrates the company’s dedication to applying meticulous, methodical processes typically reserved for cloud computing security to the burgeoning field of AI. Given the increasing centrality of AI to operational infrastructure, John argued convincingly that managing AI risks should be as rigorous and robust as managing any critical business software.

We dove deeper into AI’s role in compliance, highlighting a shift from reactive detective strategies to proactive, predictive capabilities. Compliance, historically viewed as the “business prevention unit,” has undergone significant evolution. AI-driven solutions enable the considerable acceleration of compliance operations, leading to improved outcomes and enhanced traceability. This means compliance professionals can now focus their expertise on strategic issues rather than mundane, repetitive tasks.

Byrne also linked compliance with fundamental banking principles, reminding us that compliance is not a new concept, but rather, it is rooted in maintaining trust. Banking, at its core, is about trust, and the robustness of compliance directly affects this trust. This echoes the historical narrative that compliance is not merely about following rules but also about ensuring long-term business viability and customer satisfaction. Compliance, at its best, is good business.

One of the critical compliance risks in AI highlighted during our conversation was data poisoning, a growing and increasingly significant threat. Bad actors deliberately corrupt AI training data to manipulate model outputs, creating misleading results. John pointed out that managing this risk involves rigorous data provenance checks and cleansing techniques. The objective is not only to secure data but also to validate its accuracy and integrity continuously.

We also explored the distinction between large language models (LLMs) and small language models (SLMs). While LLMs like ChatGPT excel with vast datasets, SLMs are invaluable when privacy, specificity, and accuracy are paramount, such as in proprietary compliance controls within financial institutions. John’s insights into this nuanced approach are particularly critical for compliance professionals managing highly confidential or regulated information.

Moreover, our discussion touched on traceability and auditability, key concerns for compliance practitioners. AI solutions now facilitate real-time audit trails, enabling the immediate tracing of every compliance decision, control update, and policy shift back to their origins. The emphasis is clear that automation and digitization are not optional; they should be viewed as necessary to meet current regulatory expectations effectively.

Byrne provided a powerful case study example regarding dynamic traceability, from risk identification to response, highlighting how AI can dramatically compress timeframes. Traditionally, significant regulatory changes, such as those stemming from MiFID II, would take organizations months or even years to fully operationalize. Today, AI-driven systems can manage this lifecycle in seconds. Such rapid responsiveness not only ensures compliance but also provides strategic flexibility, which is crucial in our ever-changing regulatory landscape.

Recent geopolitical developments underscored the strategic potential of compliance as a proactive risk management function. The Trump Administration’s suspension of FCPA investigation and enforcement raises questions about the role of compliance in the absence of strict regulatory frameworks. A key compliance response is embedding compliance within core business operations, as this integration is a powerful enabler rather than a mere defensive posture. Once again, we see that effective compliance drives more efficient business operations, leading to greater profitability.

Finally, we discussed the future of RegTech, which Byrne believes will democratize compliance technology. Historically restricted to larger financial institutions, advanced compliance tech is now becoming accessible to smaller entities, leveling the competitive field. This democratization ensures that sophisticated compliance is no longer the privilege of only the largest, most resource-rich banks.

In wrapping up our conversation, it became clear that AI and compliance together represent not just a shift but a leap forward, transforming compliance from a cost center into a strategic business partner capable of driving significant organizational value. It’s an exciting time to be a compliance professional as we witness firsthand how AI innovation is reshaping our roles and the very nature of compliance itself.

Stay smart, stay ethical, and, as always, stay compliant. The future is here, and AI is powering it.

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Compliance and AI

Compliance and AI: Revolutionizing Risk Management with John Byrne

What is the role of Artificial Intelligence in compliance? What about Machine Learning? Are you using ChatGPT? These are but three questions we will explore in this cutting-edge podcast series, Compliance and AI, hosted by Tom Fox, the award-winning Voice of Compliance. In this episode, Tom welcomes John Byrne, founder and CEO at Corlytics, to discuss the company’s groundbreaking ISO 42001 certification and its significance for RegTech.

They delve into the evolving role of compliance, emphasizing the transition from reactive to proactive problem-solving. John highlights the shift towards AI-centric operations at Corlytics, aiming for enhanced accuracy, consistency, and traceability in compliance processes. The conversation explores the benefits and risks of AI, including data poisoning and the practical differences between large and small language models. They also touch upon integrating compliance into core business operations, aiming for better client outcomes and speeding up processes like account opening. John envisions RegTech becoming widely accessible, benefiting even the smallest regulated players by enabling proactive business solutions and reducing bottlenecks.

Key highlights:

  • ISO 42001 Certification and Its Importance
  • AI in Compliance and Security
  • AI as an Everyday Tool in Banking
  • Large Language Models vs. Small Language Models
  • Data Poisoning and Its Risks
  • Dynamic Traceability and Policy Lifecycle
  • Compliance as a Strategic Risk Management Tool

Resources:

John Byrne on LinkedIn

Corlytics

Tom Fox

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Check out my latest book, Upping Your Game: How Compliance and Risk Management Move to 2030 and Beyond, available from Amazon.com.

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Everything Compliance - Shout Outs and Rants

Everything Compliance – Shout Outs and Rants: Episode 154

Welcome to this edition of Everything Compliance, Shout-Outs, and Rants. This episode features Matt Kelly, Jonathan Marks, Karen Woody, Tom Fox, and Karen Moore.

  1. Karen Moore shouts out to her nephew, who graduates from Georgetown Law School this week, and to the NFL superfan for allegedly causing Shedeur Sanders to drop to the 5th round before being drafted in the recent NFL Draft.
  2. Matt Kelly rants about the GOP’s attempt to ban states from regulating AI.
  3. Jonathan Marks rants about MLB caving to President Trump and allowing those who bet on baseball back into the fold.
  4. Karen Woody shouts out to the Washington & Lee Law School graduating class of 2025.
  5. Tom Fox shouts out to the Disney TV series Andor.

The members of 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.