Categories
Daily Compliance News

Daily Compliance News: September 28, 2026,  The Falling Behind 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:

  • Foreign banks now after UBS. (Reuters)
  • Governments being left behind by AI. (NYT)
  • Former Indonesian Education Minister’s corruption conviction upheld. (Bloomberg)
  • Manchester City corruption hurting UK/UAE relations. (FT)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

Categories
AI Today in 5

AI Today in 5: September 28, 2026, The $1 Billion Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. Governments being left behind by AI. (NYT)
  2. AI tools for employment raise privacy and compliance challenges. (Ogletree Deakins)
  3. Oz says AI will drive up healthcare costs. (Healthcare Dive)
  4. AI scams top Italian bank. (Reuters)
  5. Insurers say AI driving up hospital costs by nearly $1bn. (Reuters)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

Categories
2 Gurus Talk Compliance

2 Gurus Talk Compliance: The Slop Grenades Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart on 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

Stories This Week Include:

  • Former Vitol trader Javier Aguilar sentenced to 4 years.   (Bloomberg)
  • Russia seizes control of Nestle operations.  (WSJ)
  • The Class ceiling in America.   (NYT)
  • SEC rollback puts audit fees at risk. (FT)
  • Must AI companies disclose ‘dangerous events’? (Reuters)
  • OpenAI Discloses Six New Incidents of ‘Concerning’ A.I. Behavior. (NYT)
  • Shopify CEO says employees’ ‘slop grenades’ are making more work for everyone else. (Fortune)
  • Payments Scandal Rocks LA Clippers. (Radical Compliance)
  • Florida man dressed in full jester costume arrested for pulling 12-inch dagger on landscaper over loud mowing. (AOL)
  • The EU AI Act Is No Longer Theoretical. (Volkov Law)

Resources:

Kristy

Kristy Grant-Hart on LinkedIn

Order Kristy’s updated 10-year new edition of How to Be a Wildly Effective Compliance Officer by clicking here.

Tom

Check out Tom on LinkedIn

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

Categories
Daily Compliance News

Daily Compliance News: September 25, 2026, The PE and Law Firms 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:

  • Creating world AI controls via group chat. (WSJ)
  • Corruption shaking up the Brazilian Presidential election. (NYT)
  • The monster behind Russia sanctions evasion. (NYT)
  • Private Equity will pay out to lawyers. (FT)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

Categories
Compliance and AI

Compliance and AI: SendSafely’s Brian Holyfield on Shrinking the Blast Radius

What is the intersection of AI and 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, host Tom Fox visits Brian Holyfield, Co-Founder & Chief Product Officer at SendSafely.

Holyfield’s background in ethical hacking and real-world security testing shapes his practical view of cybersecurity. He believes compliance should reflect how breaches actually happen, especially through vendors and service providers, which means organizations must look beyond their own perimeter. For him, data minimization and retention controls are essential: companies should keep only the data they truly need, delete unnecessary copies, and limit where sensitive information lives. Holyfield also stresses reducing the blast radius, arguing that the best defense is to assume a breach will occur and design systems so attackers can access as little data as possible for as short a time as possible.

Key highlights:

  • Preventive AI governance through data minimization
  • Deliberate configuration choices that shrink breach blast radius
  • Aging Out Data Into Secure Backend Archives
  • Native end-to-end encrypted storage for regulated attachments
  • Trust Layer for End-to-End Encrypted Regulated Data

Resources:

SendSafely

Brian Holyfield on LinkedIn

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Everything Compliance

Everything Compliance: The Conflicts of Interest, The False Claims Act, AI and More AI Edition

Welcome to a revamped Everything Compliance. We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Matt Kelly, Jonathan Armstrong, and Karen Moore for the next iteration of Everything Compliance. This episode features a cross-Atlantic discussion on emerging compliance issues. Fan favs Shout Outs and Rants end this week’s episode.

  • Karen Moore looks at the growing Federal trend of bringing False Act Claims against corporate DEI programs.
  • Jonathan Armstrong describes the first public GDPR report of an AI agent attack and offers nine responses.
  • Rebecca Walker reviews key data from Navex anonymized disclosures, including COIs.
  • Matt Kelly looks at recent guidance from the New York State Department of Financial Services on AI risk assessment.

The members of Everything Compliance are:

The award-winning Everything Compliance is a part of the Compliance Podcast Network.

Categories
AI Today in 5

AI Today in 5: September 24, 2026, The Complicating Compliance Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. Flock says it will set limits. (WSJ)
  2. Mental health strains on AI workers. (FT)
  3. Does the EU AI Act complicate compliance? (IAPP)
  4. Boards say they need more from management on AI. (CCI)
  5. Compliance teams struggling with AI auditing. (FinTech Global)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

Categories
AI Today in 5

AI Today in 5: September 23, 2026, The AI Swarm Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. NY state to explore kill switch requirement for AI.(Insurance Journal)
  2. Feds stalled in AI regulation; states not so much. (CCI)
  3. AI and the CX problem. (CX Today)
  4. Anthropic releases ‘safest’ AI model.  (NYT)
  5. What is an AI swarm? (CBS News)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

Categories
Blog

Da Vinci Week: Part 3 – Leonardo’s Flying Machines and “Can We?” or “Should We?”

In the first two posts in the Leonardo Compliance Framework, the Mona Lisa gave us Refine, the principle that an effective compliance program improves as the organization learns from experience. Leonardo’s anatomical studies gave us Investigate, the discipline of looking beneath misconduct to understand root causes, control failures, incentives, management decisions, and the organizational systems that produced the outcome. The third principle is Innovate.

For that lesson, we turn to Leonardo’s studies of flight and his designs for flying machines. Leonardo examined birds, air movement, wings, and mechanical systems as he considered whether technology could allow human beings to fly. Many of his concepts were far beyond the practical capabilities of his time, but they demonstrate an important characteristic of Leonardo’s work: he imagined capabilities that did not yet exist and then studied the systems necessary to make them possible.

For corporate compliance professionals in 2026, the analogy to artificial intelligence is particularly useful. AI is expanding what companies can automate, analyze, predict, generate, and increasingly act upon. Organizations are moving beyond using generative AI to draft documents and summarize information. AI systems are becoming embedded in business processes, interacting with corporate data, supporting consequential decisions, communicating with customers, evaluating third parties, and, through increasingly agentic capabilities, taking actions that previously required human intervention.

The compliance challenge is not whether companies should innovate. They will. The challenge is establishing governance that lets innovation create business value without creating unmanaged legal, ethical, operational, or compliance risk.

AI Governance Is Enterprise Governance

Compliance professionals have sometimes approached emerging technology as primarily the responsibility of IT, Cybersecurity, Data Privacy, or Legal. That division becomes increasingly difficult with AI because these systems can influence many of the activities a corporate compliance team already oversees. Indeed, the Evaluation of Corporate Compliance Programs (ECCP) anticipates these very concepts in its 2024 edition.

AI may assist with third-party due diligence, contract review, procurement, transaction analysis, hiring, customer communications, investigations, fraud detection, marketing, or pricing. Each application creates a different risk profile. A due diligence system may generate inaccurate information about a business partner. An investigation tool may expose privileged or confidential information. A sales application may generate communications inconsistent with company policies. An agent connected to corporate systems may take actions that historically required human approval.

The ECCP asks the following:

  • How does the company assess the potential impact of new technologies, such as artificial intelligence (AI), on its ability to comply with criminal laws?
  • Is management of risks related to the use of AI and other new technologies integrated into broader enterprise risk management (ERM) strategies?
  • What is the company’s approach to governance regarding the use of new technologies such as AI in its commercial business and in its compliance program?
  • How is the company curbing any potential negative or unintended consequences resulting from the use of technologies, both in its commercial business and in its compliance program? 

Visibility and Risk Should Drive the Control Environment

By 2026, asking whether a company uses AI provides little useful information. Management needs to understand how AI is being used and what authority particular systems possess. A tool that summarizes a public document presents a very different risk profile from a system that influences hiring, approves a third party, communicates with customers, accesses confidential information, initiates a transaction, changes corporate records, or takes actions across interconnected systems.

An AI inventory should therefore identify meaningful use cases, including the business owner, intended purpose, relevant data, third parties involved, decisions influenced by the technology, degree of autonomy, and applicable controls. The objective is not simply to count tools. It is to give management sufficient visibility to identify where material risk exists.

That visibility should support risk classification. Not every AI application requires the same level of governance. Classification should consider the system’s purpose, data sensitivity, potential consequences of error, degree of autonomy, affected populations, ability to review or reverse decisions, and applicable legal or regulatory requirements.

This is familiar territory for compliance professionals. Risk-based programs have long applied different levels of scrutiny to third parties, transactions, investigations, and markets. AI should follow the same principle. Higher-risk systems should receive greater review, stronger controls, and more rigorous monitoring.

Human Oversight Must Preserve Accountability

“Human in the loop” has become common language in AI governance, but a human’s presence alone does not create an effective control. Meaningful oversight requires defined responsibilities, appropriate expertise, sufficient capacity to review relevant outputs, and authority to challenge or override the system.

If one employee is nominally responsible for reviewing thousands of AI-generated recommendations each day, human oversight may exist on paper but not function in practice. The same problem arises when employees routinely accept recommendations because they assume the technology is more reliable than their own judgment.

The control should therefore define the reviewer’s responsibilities, the circumstances requiring additional scrutiny, the authority to reject recommendations, and how to handle material overrides or recurring disagreements between the system and human decision-makers. Most importantly, technology should not create an accountability vacuum. If an AI system contributes to a compliance failure, the organization should still be able to identify the business process owner, who approved the use case, who monitored it, and who had authority to intervene.

This becomes increasingly important with agentic systems. Traditional corporate controls generally assume identifiable human actors approve payments, create vendors, review contracts, or authorize higher-risk third parties. When technology performs some of those activities, the organization has effectively delegated authority to a system. The control environment must reflect that delegation while retaining human and organizational accountability for the outcome.

Third-Party AI and Data Risk

Many companies will obtain significant AI capabilities from external vendors rather than develop them internally. Using a vendor does not transfer accountability for the resulting compliance risk. Traditional third-party risk management principles remain relevant. The company should understand the service provided, the information the vendor receives, how data are used and retained, which subcontractors are involved, how incidents are managed, and what contractual rights the company has to obtain information, require remediation, audit, or terminate the relationship.

AI adds a dynamic element because models, features, and business uses can change after initial approval. Monitoring should therefore identify material changes in functionality, data use, vendor practices, or business application that could alter the original risk assessment.

Data governance is equally important. Companies need clear rules regarding which AI systems may access confidential business information, personal data, investigation materials, privileged communications, customer information, trade secrets, source code, and other sensitive information. As enterprise AI systems increasingly operate on internal data, blanket prohibitions will often give way to more precise governance defining approved systems, permissible data, access controls, retention, deletion, and accountability.

These issues require coordination across Compliance, Legal, Privacy, Cybersecurity, IT, Records Management, and the business. Effective governance depends upon clear responsibilities rather than overlapping or fragmented ownership.

Test Before Deployment and Monitor Afterward

Leonardo’s flying machines provide another useful innovation lesson. Test a design before you trust it with a critical task. AI testing should match the risk. Before deployment, the company should understand whether the system performs as intended, where its limitations lie, how it responds to unusual circumstances, whether users can manipulate it, and whether inaccurate or inconsistent outputs could create material consequences. Testing at implementation is not enough. Business conditions change, vendors update models, employees develop new uses, and system capabilities expand. An application that operated within acceptable parameters when approved may later present a different risk profile.

Higher-risk systems therefore require post-deployment monitoring that can identify performance issues, material changes, incidents, and circumstances requiring reassessment. Management should also establish when a system should be modified, restricted, or suspended.

This lifecycle approach connects Innovate to the next Leonardo principle, Monitor. Responsible innovation is not a one-time approval. Governance should continue throughout the period the organization relies on the technology.

Using NIST and ISO as Governance Architecture

Compliance professionals do not need to invent an AI governance structure from scratch. The NIST AI Risk Management Framework provides a useful approach to governance, mapping, measuring, and managing AI risk, while ISO/IEC 42001 offers a management-system perspective built around responsibilities, processes, documentation, monitoring, and continuous improvement.

For the CCO, the value lies in providing governance architecture, not another checklist. The relevant measure is not whether a company can say it follows NIST or ISO. It is whether its governance system addresses the actual risks created by its AI applications and whether the resulting controls work in practice. Frameworks provide structure. Management remains responsible for operating the system.

Compliance Should Enable Responsible Innovation

The CCO should avoid two extremes: allowing enthusiasm for AI to outrun governance or creating an approval structure so burdensome that employees circumvent it. A better model is responsible innovation. Compliance can help create clear pathways for lower-risk experimentation while ensuring that higher-risk applications receive appropriate scrutiny. Employees should understand what uses are permitted, which require approval, what categories of information may be used, and when escalation is necessary.

This approach also creates opportunities for a corporate compliance program. AI may improve due diligence, transaction monitoring, investigations, risk assessment, training, and data analysis. The compliance function should be willing to explore those capabilities under the same risk-based governance it expects the business to follow.

A CCO’s contribution should not be measured by how much innovation Compliance prevents. It should be measured in part by whether Compliance helps the enterprise capture value while maintaining appropriate accountability and control.

Before Leaving the Ground

Leonardo’s flying-machine studies represent the willingness to imagine possibilities beyond current practice. The modern compliance lesson is to combine that willingness with disciplined governance. For the CCO, Innovate means helping the enterprise pursue new capabilities through a risk-based system that provides visibility, assigns ownership, preserves meaningful human accountability, tests higher-risk applications, and monitors them as technology and business use evolve. The objective is neither unrestricted adoption nor blanket prohibition. It is responsible innovation that can produce sustainable business value.

From Innovation to Monitoring

Responsible innovation does not end when technology is approved and deployed. The organization must determine whether systems continue to operate as intended as data, users, vendors, business conditions, and risks change. That brings us to the fourth Leonardo principle: Monitor.

In Blog Post Four, The Last Supper and the Danger of Deterioration, we will use Leonardo’s experimental masterpiece to examine the difference between implementing a control and demonstrating that it remains effective. The discussion will focus on control testing, continuous monitoring, compliance analytics, ownership, remediation, AI monitoring, and the board’s role in evaluating evidence of continuing program effectiveness.

Categories
TechLaw10

TechLaw10: AI & Its Impact on Law Firms with guest Jill Kawakami

In this episode of TechLaw10, Punter Southall Law’s Jonathan Armstrong & Eric Sinrod, Professor, and Duane Morris LLP attorney, chat with a returning special guest, Jill Kawakami. This is episode 302 in the popular TechLaw10 series. You can listen to earlier podcasts here. Jill, Jonathan & Eric discuss several issues, including:

  • how AI has changed law firms
  • what are the concerns of junior lawyers, and what do they want from a post-AI world?
  • the economics of the use of AI in the law
  • what seems to be the world’s first ban for a lawyer for hallucination
  • some of the positive uses for AI in the law
  • the issues with access to justice
  • the impact on privilege
  • how law firms can grade AI use
  • how law firms can deal with the scrutiny gap
  • what some law firms are doing to train their lawyers
  • the issues with token wastage
  • the latest figures on AI reducing headcount
  • the issues with AI anxiety
  • AI displacement
  • the impact on diversity & social advancement

Jonathan talks about the Abhishek Kumar case. There’s a copy of the Tribunal’s judgment here.

Jonathan & Eric refer to Damien Charlotin’s database on hallucinations, which is here. There’s a summary of hallucination cases in the UK, including the Ayinde case, which Jonathan mentions here. The NYSBA paper Jonathan talks about is here.

Jonathan also talks about the EU AI Act. FAQs are here. A glossary of AI terms is also available here. You can find out more about Jonathan Armstrong here. You can find out more about Eric Sinrod here.