Categories
2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 86 – The BOA 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 this week’s latest compliance issues!

Stories This Week Include:

  • Memo to Law Firms: Don’t call your clients stupid in emails. (FT)
  • John Carreyrou exposes You Can See Everything. (NYT)
  • What do AI agents talk about at dinner parties? (NYT)
  • Are you ready for a new AML Program? (Crime Corruption Compliance)
  • 6 Key themes from Inside the Mind of the CCO. (Compliance Week)
  • Bank of America to Pay $1.2 Billion to Settle Violations of Money Laundering, Sanctions Laws (WSJ)
  • Tech CEO connects Grok Bot to bank account and instantly regrets it (CyberNews)
  • AI in Investigations: What Courts Are Saying (So Far) About Privilege (Corporate Compliance Insights)
  • Courts Grapple With Problem of People Betting on the Outcome of Jury Cases (WSJ)
  • Scuba-clad man robs Disney Springs restaurant, swims away (WFTV)

Resources:

Kristy

Kristy Grant-Hart on LinkedIn

Order Kristy’s updated 10-year edition of How to Be a Wildly Effective Compliance Officer 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

Categories
Daily Compliance News

Daily Compliance News: October 22, 2026, The CCOs as Strategic Advisors 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 cover four stories from the business world, compliance, ethics, risk management, leadership, or general interest for compliance professionals.

Top stories include:

  • The Cornell scandal offers lessons for high-stakes internal reviews. (Bloomberg Law)
  • You can use ‘compliance’ and corruption in laws. (Trend.az)
  • CCOs as strategic advisors. (CCI)
  • AML tech improving compliance. (TechBullion)

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

Categories
Compliance Into the Weeds

Compliance into the Weeds: Bank of America’s $1.2B AML Breakdown: Too Big to Remediate?

The award-winning Compliance into the Weeds is the only weekly podcast that dives deep into compliance-related topics, going into the weeds to uncover hard-hitting compliance insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against BAO for $1.2bn.

The enforcement action against Bank of America (with OCC, FinCEN, OFAC, and others) was for BOA’s failure to maintain an effective Bank Secrecy Act/AML program, including flawed transaction monitoring that led to inadequate suspicious activity reporting, weak customer due diligence, and deficient sanctions screening, sometimes with law enforcement flagging issues to the bank rather than the reverse.

They place this alongside recent actions against UBS, American Express, and a New York DFS fine of SEB, arguing recurring failures stem from poor transaction analysis. Kelly ties Bank of America’s problems to its homegrown “Event Processor” system, launched in 2010, which critics say uses arbitrary risk-scoring thresholds and lacks recalibration, compounded by insufficient staffing and management support. They highlight governance and accountability concerns, including unresolved findings from a 2024 OCC order, questions about board oversight of compliance, and doubts that fines alone will drive lasting remediation.

Key highlights:

  • BofA Fine Breakdown
  • What Went Wrong in AML
  • How the Tech Failed
  • Leadership and Culture Accountability
  • Fixing It People and Oversight
  • Risk Assessments and Too Big to Remediate

Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance Report

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.

Categories
Compliance Into the Weeds

Compliance into the Weeds: Amex AML Enforcement: Credit Card Risk, SAR Failures, and Board Accountability

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance topics, literally going into the weeds. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against American Express.

The penalties included a $350 million civil penalty, cease-and-desist orders, and extensive compliance obligations tied to weaknesses in customer due diligence, suspicious activity reporting, staffing, and risk assessment. Tom highlighted that Amex processed billions of transactions, many ordinary credit-card transactions, showing banks must know all customers, not just high-dollar activity, and noted regulators’ broader pattern of similar actions across the industry as financial innovation outpaced compliance investment.

Matt noted that regulators depend on SARs as critical inputs for broader enforcement “mosaics,” explaining why SAR failures draw intense scrutiny. The orders’ notable feature is direct board involvement, requiring a board-level compliance committee and action plan to hold management accountable, with a strong focus on end-to-end documentation and evidence trails; they see no facts suggesting the egregious, employee-involved criminality seen in TD Bank.

Key highlights:

  • Industry Pattern and Root Causes
  • Innovation as Compliance Risk
  • Board Oversight Mandates
  • Why SARs Matter
  • DOJ Risk and TD Bank Comparison
  • Disjointed Compliance and Fixes

Resources:

Tom in the FCPA Compliance Report, Part 1 and Part 2

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.

Categories
Daily Compliance News

Daily Compliance News: September 16, 2026, The Flipped 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:

  • China used Binance to launder Iranian money, prosecutors say. (NYT)
  • The empire of grift. (The Atlantic)
  • Ex-Vitol trader paid during trial and after guilty conviction. (Bloomberg)
  • Maduro ally to change plea to guilty. (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
Daily Compliance News

Daily Compliance News: September 15, 2026, The Bureaucratic Zeal 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:

  • Collapse of the ‘Montessori Ponzi.’ (NYT)
  • Winning big on Polymarket against KPMG clients. (WSJ)
  • Ex-Ukraine PG accuses ABC chief of falsifying documents. (Meduza)
  • Prince Michael of Liechtenstein says AML disclosure rules have gone too far. (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 15, 2026, The Medical AI 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. What’s holding back AI in financial services? (FinTech Global)
  2. EU demands AI companies meet safety requirements. (The Jerusalem Post)
  3. Data quality is holding back AI in banks. (Asian Banking & Finance)
  4. Cybersecurity enhanced with AI. (FinTech Magazine)
  5. Trump Administration moving to deploy AI in medicine. (NYT)

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
FCPA Compliance Report

9/11 Twenty-Five Years Later: Part 3: Alex Dill – Patriot Act: The AML Response to Terrorist Threats

Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget.

On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Today Tom’s guest is Alex Dill. Alex is a scholar and professor specializing in financial regulation, risk management, and compliance. He also has corporate experience in ​the ethics of business practices in finance, bankruptcy, bond covenants, and debt markets. He joins Tom to discuss the Patriot Act’s impact on responding to terrorist threats.

How 9/11 Changed AML

Before 9/11, AML regulations were very lax and backward-looking. The focus was on prosecuting crimes already committed and on money laundering more than on terrorist financing. Banks weren’t doing meaningful customer due diligence because they felt the process was invasive. After 9/11, this all changed. Law enforcement agencies and financial institutions revamped their policies and procedures to take a more preventive approach to AML and terrorist financing. This led to the Patriot Act.

The Financial Response

Tom asks Alex whether he saw a similar regulatory response among non-financial institutions regarding Patriot Act AML procedures post-9/11. “There was a huge amount of rulemaking that had to be done,” Alex responds. He adds that public companies adopted customer due diligence and applied it more broadly across sectors, using a risk-based approach. Companies now had to file suspicious activity reports, not just banks. Customer identification was also introduced. “The Patriot Act sought to encourage cooperation among law enforcement agencies and among the financial institutions themselves to share information and obtain information from foreign law enforcement authorities,” Alex tells Tom.

The Challenge With The Patriot Act 

Alex explains to Tom that the Patriot Act has challenges. A major challenge is detecting the financing behind these attacks. Funds that finance these actions come from both legal and illegal sources, and that is a major issue. Transaction amounts can be small, which may pose a risk for some compliance officers. 

Technology in Anti-Terrorism

Alex remarks that technology is very important in the fight against terrorism, as it has changed how we function in our world. The downside is that technology has also helped create some of the compliance issues we face today. Social media platforms have helped to create polarization in society, and criminals have used programs like cryptocurrency for money laundering and financing terrorism. However, Alex ends on a positive note, saying the AML Act of 2020 has been helping curb these issues.

Resources:

Alex Dill | ⁠LinkedIn⁠ | ⁠Twitter

Categories
FCPA Compliance Report

9/11 Twenty-Five Years Later: Part 2: Juan Zarate – The Treasury Department Responds

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget.

On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Juan Zarate is the Global co-Managing Partner and Chief Strategy Officer at K2 integrity. On 9/11 he was a prosecutor at the Treasury Department working on international enforcement issues, anti money laundering, anti-corruption and anti-terrorist financing. He joins Tom Fox to commemorate the 20th anniversary of 9/11. They discuss how his role changed, the Treasury Department response and what the tragic event means for him.

A Change of Mission

9/11 changed the mission of the Treasury Department. Juan tells Tom, “We went after terrorist financing to try to disrupt and dismantle Al-Qaeda’s terrorist networks and infrastructure, and disrupt how illicit financing was flowing through the international system.” He recalls where he was on the fateful day and how seeing the smoke from the Towers and the Pentagon affected him emotionally. Something very different was happening, he recalls; the country was under attack.

He outlines the strategic, departmental and tactical changes implemented after 9/11 to fight terrorism. The President declared that we were now at war. “The attitude and the strategic direction of the government was [that] we now have to prevent terrorist attacks,” Juan recalls. “We have to disrupt and dismantle terrorist networks. And that led to an entire preventative paradigm for the counter-terrorism approach to the government.” The new mission of the Treasury Department was the following areas, Juan remarks: “How do you use financial information more aggressively? How do we think about the use of tools and authorities that the Treasury has, like sanctions, anti money laundering rules? How do we think about the relationships internationally with central banks, finance ministries? How do we get the world on board to disrupt terrorist financing, to rip these organizations out of the legitimate financial commercial world?” The Patriot Act was one tactical change, among others, that was implemented to achieve the new mission of fighting terrorism.

What 9/11 Means

Tom asks Juan, “What are your reflections now as we come up on the 20th anniversary of the day of 9/11, and really what it meant for America and for you 20 years later?” Juan responds that he has mixed emotions. He thinks about the victims and their families first of all. That day changed history, he says. “It changed the way that the U S government viewed the world. It changed the way that we operated our strategy. And it changed the sense of our vulnerability.” The recent events in Afghanistan make the 20th anniversary even more difficult for Juan. “I have very mixed emotions coming on the 20th anniversary of 9/11,” he concludes, “but I’m very proud of the work that we did. I’m proud of the people I served with and my sympathies go out to the victims and their families.”

Resources

Juan Zarate at ⁠K2 Integrity⁠

Categories
FCPA Compliance Report

9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo – Needing to Make a Difference

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget.

On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Tom’s first guest this week is Gabe Hidalgo, anti money laundering compliance expert, who shares how the events of that fateful day changed the course of his career.

Looking Back

Gabe – who worked as outside counsel for insurance companies at the time – remembers turning on YahooTV as soon as he got to his office on 9/11 and seeing the second plane hit the World Trade Towers. He knew immediately that it was a deliberate attack. “I knew that this was kind of a hallmark moment,” he tells Tom, “that this was not an accident.” He details leaving the office in haste to get to his pregnant wife, and the obstacles and roadblocks he faced on the way. When they finally reunited at home, they were overcome with emotion. He remembers feeling gutted thinking about the unborn children who would grow up never knowing their fathers.

Needing to Do Something

Gabe needed to do something more than just shed tears about 9/11, he tells Tom. He started to think about how he could use his skills as an attorney. “I went down the path of looking in private industry, what I can do, and came across anti money laundering compliance, which I thought was fascinating. And I said to myself, I need a way for me to be able to get into that so that I can start making a difference.” He shares his journey into the field, and that it was exactly the right time and the right fit for him. 9/11 was a wake up call for America, he remarks. It made us realize that we need to do whatever we can to prevent anything similar from happening again.

Evolution of AML Since 9/11

Tom asks Gabe how AML compliance has advanced since 9/11. It’s much more difficult for terrorist financiers to move funds now, he responds. “A lot of institutions have strengthened and hardened their compliance programs to the point where they can monitor individual transactions as they’re moving across the transactional workflow in the United States. They examine each and every transaction that’s coming across from a correspondent banking perspective, which is probably one of the most high-risk channels for money movement.” Gabe and his colleagues have done great work over the past 20 years, which has helped law enforcement stop and apprehend would-be terrorists. However, we can’t be complacent, Gabe says.

Tom asks what 9/11 means for America. The 20th anniversary is a somber one, Gabe replies. 9/11 taught us not to be naive, that we’re not as protected as we think we are. He is proud of the advancements made to keep everyone safe, but the work continues. “It’s a moment of reflection,” he points out. “We need to think about not only the people who have lost their lives, but everyone that was impacted – whether they were directly impacted through a family loss, or they were emotionally impacted by what actually occurred.”

Resources

Gabe Hidalgo on ⁠LinkedIn⁠