Tag: CCO

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Building a Data-Driven Culture: A Compliance Imperative in the Age of AI

I recently read an article in the Sloan Management Review entitled “Building a Data-Driven Culture: Four Key Elements” by Ganes Kasari, founder and CEO at Tensor Planet. He posits that a data-driven culture is vital to success with AI projects, but shaping one involves many challenges. He suggests that learning how to build one from organizations that have made the journey engaging for employees is one approach to take. For compliance professionals, this is a critical issue. Compliance, risk management, and governance efforts may be ineffective if a company’s workforce does not instinctively turn to data when making decisions.

The Department of Justice’s (DOJ) 2024 Update on the Evaluation of Corporate Compliance Programs (2024 ECCP) has made it clear that compliance programs must be data-driven, proactive, and continuously monitored. But if an organization has not built a culture of data-driven decision-making, compliance will always be playing catch-up.

So, how do companies foster a data-driven compliance culture? Kasari says the answer lies in four key areas:

  1. Leadership Intervention
  2. Data Empowerment
  3. Collaboration
  4. Value Realization

Leadership Intervention: Setting the Tone from the Top

For a compliance program to be truly effective, proactive, and data-driven, leadership must take an active role in championing the importance of data in decision-making. Too often, executives fund compliance initiatives but delegate execution entirely to compliance and IT teams. The result? Employees still see compliance as someone else’s job rather than an integral part of business operations.

The DOJ has emphasized that compliance programs must have engaged leadership. That means:

  • Executives must communicate why data and AI are essential for compliance.
  • Leaders must use data themselves, modeling the behavior they expect from their employees.
  • Regular check-ins and accountability measures should ensure compliance is not just an IT issue but an enterprise-wide priority.

Concept in Action: Rewarding Compliance Innovation at DBS Bank

When DBS Bank launched its digital transformation initiative, CEO Piyush Gupta prioritized creating a culture that rewarded data-driven decision-making and innovation. In one case, an employee made a data-driven compliance decision, ultimately leading to a failed experiment. There was regulatory pressure to penalize the employee, but Gupta stepped in and awarded them instead—for trying, learning, and embracing the new compliance culture.

This kind of visible leadership support sends a powerful message: compliance isn’t just about avoiding penalties but also about building a smarter, more resilient organization.

Data Empowerment: Making Compliance Everyone’s Job

For compliance to be truly embedded in company culture, every employee, not just compliance officers, must be able to access, understand, and act on data.

This means focusing on three levels of readiness:

  1. Data Readiness – Ensuring high-quality data is available at the right time to the right people.
  2. Analytical Readiness – Training employees to interpret compliance data and make informed decisions.
  3. Infrastructure Readiness – Investing in AI-driven compliance tools, automation, and real-time risk monitoring systems.

Concept in Action: JPMorgan Chase and the DeepRacer Challenge

JPMorgan Chase wanted to upskill employees in AI and data analytics. Instead of boring compliance training sessions, the company introduced a global challenge using AWS DeepRacer, a competitive coding event where employees programmed autonomous vehicles to race.

Employees learned data analytics, AI programming, and machine learning principles while having fun. The result? Thousands of employees became data-literate, able to apply AI-driven insights to compliance, risk management, and fraud detection.

Collaboration: Breaking Down Compliance Silos

Too often, compliance sits in its bubble, siloed from business operations. However, in an AI-driven world, compliance must be embedded in every department, from finance and HR to product development and supply chain management.

A major barrier to compliance collaboration is language. Compliance teams often use technical jargon, while business teams use operational language. The result? Miscommunication, resistance, and confusion.

To fix this, compliance functions must invest in:

  • Cross-functional compliance training so business leaders understand compliance risks.
  • Compliance “translators”—employees who bridge the gap between compliance and business operations.
  • AI-powered compliance dashboards that translate risk into actionable business insights.

Concept in Action: Gulf Bank’s Data Ambassador Program

Gulf Bank wanted to embed data-driven compliance across its 1,800 employees. Instead of relying solely on compliance officers, the bank created a network of data ambassadors—employees across departments trained to champion compliance best practices.

The results were impressive: employees felt more ownership over compliance decisions, and the company saw a significant reduction in compliance violations.

Value Realization: Measuring and Celebrating Compliance Success

One of the companies’ biggest mistakes is treating compliance as a cost center rather than a value driver. Compliance isn’t just about avoiding fines—it’s about driving better business decisions.

To ensure compliance is seen as a competitive advantage, companies must:

  • Define clear KPIs to measure compliance impact.
  • Track and communicate compliance success stories internally and externally.
  • Tie compliance initiatives to tangible business outcomes (e.g., revenue growth, cost savings, enhanced brand reputation).

Concept in Action: AI-Powered Warehouse Compliance at a Logistics Firm

A cold chain logistics company struggled with inefficient warehouse scheduling, leading to regulatory fines and supply chain bottlenecks. The compliance team introduced an AI-driven scheduling system, analyzing weather data, shipment history, and supplier reliability to optimize deliveries.

The results?

  • 16% reduction in turnaround time
  • $1.2 million saved annually in avoided fines
  • Increased customer satisfaction

To celebrate this success, the company shared the story through internal newsletters, town halls, and webinars, ensuring that employees saw compliance as a strategic enabler rather than just a legal requirement.

Compliance in the Age of AI

The DOJ’s 2024 guidance has made it clear that compliance programs must be data-driven, proactive, and continuously monitored. But simply investing in AI tools isn’t enough. Companies must build a truly data-driven culture where compliance is instinctive, embedded, and embraced across all levels of the organization.

The key takeaways?

  1. Leadership must champion compliance—not just fund it.
  2. Compliance must be accessible, understandable, and actionable for all employees.
  3. Cross-functional collaboration is essential to break down compliance silos.
  4. Compliance success must be measured, celebrated, and tied to business impact.

In 2025 and beyond, companies that embed AI-driven compliance into their culture will not only avoid regulatory fines and penalties or even FCPA violations, but they will also gain a competitive edge in an increasingly complex business world.

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Daily Compliance News

Daily Compliance News: February 3, 2025, The Division of Engagement and Compliance 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:

  • Congress says Nvidia chip flow to China should be stopped. (WSJ)
  • The CCO Departure Bonus. (Cosmos)
  • WVU replaces DEI with “Dept. of Engagement and Compliance”. (12WBOY)
  • Will Trump DOJ drop corruption charges against NYC Mayor? (Reuters)

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Check out The FCPA Survival Guide on Amazon.com.

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From Sanctions to AI Disruption: How Compliance Officers Can Navigate the Rapid Pace of Change

The pace of change in today’s global business environment is breathtaking. Events that unfold over a weekend can have massive implications for corporate compliance professionals by Monday morning. When there is a business change, risks constantly change. Over the past week, this was demonstrated with two seemingly unrelated but equally impactful developments:

  • The U.S. is imposing sanctions on Colombia because of its alleged failure to take back migrants, including a 25% tariff on goods imported from the country.
  • The emergence of DeepSeek, a Chinese AI company that has developed a large language model rivaling OpenAI’s ChatGPT—at a fraction of the cost.

For the compliance professional, what do these risks mean for your organization? What do you think about a framework for assessing and managing these risks as they raise critical compliance concerns spanning sanctions enforcement, export controls, supply chain transparency, and regulatory readiness? In the most recent episode of the FCPA Compliance Report, I explored these issues with Jag Lamba, CEO at Certa.ai. We focused on the Department of Justice (DOJ) framework in its 2024 Update to the Evaluation of Corporate Compliance Programs (2024 Update) to make sense of and respond to these rapid developments.

The DOJ’s framework in the 2024 Update is broken down into three key components:

  1. Is the compliance program well-designed?
  2. Is the compliance program adequately resourced and empowered to function effectively?
  3. Does the compliance program work in practice?

We applied these elements to the recent developments and explored how compliance professionals can prepare for similar shocks in the future.

  • Is Your Compliance Program Well-Designed to Handle Rapidly Emerging Risks?

The first test of a compliance program is whether it is designed to assess, identify, and mitigate risks promptly. The DOJ has emphasized real-time risk assessment—a shift from static, once-a-year reviews to continuous monitoring.

Take the U.S. sanctions against Colombia. This was not a predictable, drawn-out regulatory action. It happened over a weekend, and by Monday, businesses importing Colombian goods faced a 25% tariff with little time to prepare. Compliance officers had to:

  1. Quickly identify how much of their supply chain relied on Colombian imports.
  2. Determine if alternatives existed to mitigate the cost impact.
  3. Communicate rapidly with leadership to ensure the company could pivot operations where needed.

A traditional, slow-moving risk assessment process would have left companies flat-footed. Instead, an agile risk management system, leveraging real-time data analytics and automated monitoring, can help companies proactively spot emerging risks before they become crises.

The same logic applies to export controls in the tech sector, especially in light of the DeepSeek development. Compliance officers at major AI and semiconductor companies must now be asking:

  1. Who are our customers in Singapore and neighboring markets?
  2. Are our chips being resold or rerouted to sanctioned entities in China?
  3. Do we have automated tools to track and verify shipments to ensure compliance with U.S. export control laws?

It may be too late to prevent regulatory scrutiny if a company relies on manual risk assessments and outdated compliance processes.

  • Is Your Compliance Program Adequately Resourced and Empowered?

The DOJ has clarified that a compliance program is only as good as the resources allocated to it. Ten years ago, the conversation centered around whether compliance officers had direct access to the board. The conversation then shifted to the quality of your Chief Compliance Officer (CCO) and compliance personnel. Today, the discussion is shifting to whether compliance has the technology, data, and personnel necessary to operate effectively.

Consider the situation with NVIDIA and its skyrocketing sales in Singapore—a market that, while business-friendly, is geographically close to countries facing strict U.S. export controls. Regulators are undoubtedly scrutinizing this data. The question for NVIDIA’s compliance team is:

  1. Do they have the visibility to track where these chips are ending up?
  2. Are they able to monitor sales intermediaries in real time?
  3. Can they preemptively flag anomalies—such as a single country purchasing a huge volume of restricted technology?

Without AI-driven compliance monitoring and data analytics, even the best compliance teams risk being overwhelmed by the sheer volume of transactions and regulatory changes.

Similarly, companies impacted by the Colombian tariffs must ensure their compliance programs have the right supply chain monitoring tools to:

  1. Identify impacted suppliers instantly.
  2. Assess alternative sourcing options without regulatory hurdles.
  3. Develop contingency plans to mitigate financial and operational risks.

This compliance function cannot be effectively run using spreadsheets and email chains. Companies must invest in data automation, AI-driven analytics, and cross-functional collaboration tools to avoid such fast-moving regulatory changes.

  • Does Your Compliance Program Work in Practice?

Finally, compliance programs must not exist solely on paper but must demonstrate real-world effectiveness. The DOJ’s 2024 Update mandates data-driven evidence to assess whether a compliance program is functional and effective.

This means compliance teams must be able to show:

  1. How many third-party vendors and intermediaries have been vetted and monitored?
  2. How export controls are enforced in practice—not just documented in policy.
  3. How quickly can the company respond to a sudden regulatory change, such as the Colombian sanctions?

One of the best ways to demonstrate effectiveness is through compliance storytelling. A compliance officer should be able to present:

  • This is a clear narrative backed by data showing how the company detected and addressed a regulatory risk before it became a crisis.
  • These are case studies of how compliance actions have improved business outcomes—for example, reducing onboarding time for sales intermediaries without compromising compliance integrity.
  • Tangible evidence includes video training logs, compliance dashboards, and documented decision-making trails.

A powerful example comes from a Fortune 100 company that secured five years of compliance funding in one go rather than having to renegotiate budgets annually. How? By presenting compliance in business terms:

  • Demonstrating how compliance efficiencies improved sales and reduced onboarding delays.
  • Showing the financial impact of proactive risk management.
  • Using data-driven evidence to justify long-term compliance investments.

This is the future of compliance: a function that prevents regulatory risk and actively contributes to business strategy and growth.

The CCO as a Strategic Risk Navigator

The recent developments with Colombian sanctions and DeepSeek’s AI breakthrough highlight how fast compliance risks can evolve. Sanctions, export controls, and regulatory enforcement actions are no longer slow-moving threats—they can materialize overnight.

The DOJ’s 2024 Update provides a clear roadmap for compliance professionals to navigate these challenges:

  1. Risk assessment must be dynamic and continuous. Compliance programs must be designed to identify risks in real-time, not just during annual reviews.
  2. Compliance must be adequately resourced. Companies must invest in technology, data analytics, and automation to meet regulatory changes.
  3. Compliance must demonstrate real-world effectiveness. Data-driven evidence, compelling narratives, and tangible business impact must back compliance programs.

Compliance professionals who embrace data-driven decision-making, automation, and proactive risk management will not only survive but thrive in this era of regulatory volatility. The question is: Is your compliance program ready for the next unexpected headline?

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What Are Agentic AI Systems, Part 1

We live in an era where artificial intelligence (AI) is no longer just a tool for answering questions or providing recommendations; it has strengthened into a partner capable of acting on our behalf. In a recent article in Bloomberg entitled Using AI Agents Requires a Balance of Trust, Privacy, Compliance, Sabastian Niles, President and Chief Legal Officer of Salesforce, discussed the role of AI agents. Today, we, therefore, enter the world of agentic AI systems. Understanding this new breed of AI is essential for compliance professionals to harness its power responsibly while safeguarding trust, privacy, and compliance. Over this three-part blog series, I will explore what Agentic AI systems are, how they can be used in compliance, and how to use Agentic AI going forward.

Defining Agentic AI Systems

In simple terms, Agentic AI does not simply inform; it acts. For compliance professionals, this opens up many possibilities for automating tasks, improving efficiency, and enhancing decision-making. However, with greater autonomy comes greater responsibility, particularly in ensuring these systems operate ethically and within regulatory boundaries.

Agentic AI systems differ significantly from traditional AI tools like chatbots or standalone large language models. While the latter is primarily reactive, responding to queries or prompts, Agentic AI systems operate with a higher degree of autonomy. These systems can analyze data, adapt to new information, and act within pre-defined parameters without requiring constant human oversight. Some of the key differences include the following.

  1. Autonomy. Unlike traditional AI, which often requires human input to execute tasks, agentic AI can take the initiative within established guidelines.
  2. Adaptability. Agentic AI learns and develops based on new data or changing conditions, making it highly dynamic.
  3. Action-Oriented. These systems can analyze data and decide and execute tasks in real time.

For example, imagine a compliance chatbot that answers employees’ questions about corporate policies. While useful, this chatbot cannot take further steps, such as generating a personalized policy report or flagging potential compliance risks. On the other hand, an Agentic AI system could handle these additional tasks autonomously, freeing compliance teams to focus on more strategic priorities.

Agentic AI in Action for Compliance

What does agentic AI mean for the compliance function? Essentially, it represents an opportunity to reimagine how compliance teams operate, enabling them to do more with less. Here are a few ways agentic AI systems can be used effectively in corporate compliance.

  1. Automating Repetitive Tasks. Compliance professionals often find themselves bogged down by routine, resource-intensive tasks. Agentic AI can take over many of these responsibilities, such as in policy management automation, by reviewing and updating compliance policies based on regulatory changes. You can provide employee support by responding to frequently asked compliance questions and escalating complex issues to the appropriate team members. You can move it outside your organization by continuously assessing third-party risks and analyzing real-time data, such as media reports or transaction histories.
  2. Enhancing Risk Assessment. Agentic AI systems can analyze vast amounts of data quickly and accurately, making them invaluable for identifying and mitigating risks. They can assist in transaction monitoring by detecting anomalies in financial transactions that may show potential fraud or corruption. You can move to more proactive risk screening by monitoring news and regulatory updates to identify emerging risks that could impact the organization. Most excitingly, they can provide predictive analytics. They could allow you to expect compliance challenges based on historical trends and current data.
  3. Supporting Decision-Making. With their ability to analyze complex data and generate actionable insights, agentic AI systems can help compliance teams make better-informed decisions. This can include scenario planning and forecasting by modeling the impact of potential regulatory changes on the organization. As the Department of Justice reminded us in the 2024 Update to the Evaluation of Corporate Compliance Programs (2024 Update), you can move to true data-driven recommendations to provide documented guidance on addressing identified risks or improving compliance processes. Finally, in the never-ending battle for resource allocation, Agentic AI can identify areas where compliance efforts should be prioritized for maximum impact.

The Risks and Responsibilities of Agentic AI

While the benefits of agentic AI are clear, compliance professionals must approach its adoption cautiously. The autonomy of these systems introduces new risks. First and foremost is data integrity and Garbage In, Garbage Out (GIGO), which tells us that AI systems are only as good as the data they process. The system’s outputs could be flawed if the data is incomplete, biased, or outdated. Accountability and transparency are critical, as the question will be asked, “When AI systems make decisions or take actions, who is ultimately responsible?” Compliance teams must establish clear guidelines to ensure accountability and transparency. Finally, there are the ethical concerns involved. The ability of agentic AI to act autonomously raises questions about transparency, fairness, and privacy. These concerns must be addressed through robust governance and ethical guidelines.

Why Compliance Professionals Should Care

Agentic AI systems are not just another tech innovation—they are a significant change that will shape the future of compliance. By understanding these systems, compliance professionals can position themselves as strategic enablers, helping their organizations harness the power of AI responsibly. Compliance teams are uniquely positioned to ensure that AI systems operate transparently and ethically, fostering stakeholder trust.

As AI-specific regulations emerge, compliance professionals will play a critical role in ensuring adherence to new legal standards, as echoed in the 2024 Update.

By integrating agentic AI into their workflows, compliance teams can improve efficiency, reduce costs, and drive profitability in the company. It will certainly demonstrate an increased ROI for compliance.

The Path Forward

The rise of agentic AI systems represents a transformative opportunity for compliance professionals, but only if implemented thoughtfully and responsibly. By embracing this technology, compliance teams can move from being seen as cost centers to becoming innovation partners, driving compliance and business success.

The key is striking the right balance: leveraging the autonomy of agentic AI to achieve efficiencies while maintaining the trust, privacy, and ethical standards foundational to compliance. As compliance professionals, we can lead this transformation, ensuring that agentic AI serves as a tool for good, not a source of risk. The bottom line is that the future of compliance is not simply about saying no to innovation; it is about guiding it responsibly. Let Agentic AI be your ally in this journey.

Join us tomorrow in Part 2, to discuss how to use Agentic AI systems.

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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:

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Adventures in Compliance

Adventures in Compliance – Compliance Lessons from ‘The Adventure of the Lion’s Mane’

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into Arthur Conan Doyle’s Sherlock Holmes collection, The Case-Book of Sherlock Holmes. It is the final set of twelve Sherlock Holmes short stories, first published in the Strand Magazine between October 1921 and April 1927. In this episode, we consider a story more from the Natural World, The Adventure of the Lion’s Mane.

In this episode, Tom dives into ‘The Adventure of the Lion’s Mane,’ a lesser-known Holmes tale set in Holmes’ retirement on Sussex Beach. The story includes a mysterious and agonizing death of a science master, initially suspected to be a murder but revealed to be caused by a lion’s mane jellyfish. This episode draws crucial compliance lessons from the narrative, such as the importance of root cause analysis, adaptability in new roles, vigilance on external risks, methodical investigations, and effective communication.

We show how Sherlockian deduction parallels the skills needed for compliance professionals to address unseen threats, adapt to dynamic environments, and ensure meticulous documentation. Tom encourages compliance officers to emulate Holmes’ analytical rigor to build robust programs tackling unexpected challenges.

Highlights include:

  • Unraveling the Mystery
  • Compliance Lessons from The Adventure of the Lion’s Mane
  • Holmes’ Investigative Techniques
  • Understanding External Risks
  • Effective Investigation Strategies
  • The Importance of Communication

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ by Dave Thompson

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 26 – CCO Authority and Independence

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 26, we ponder the evolving stature and authority of the CCO within organizations, as highlighted by recent guidelines and regulations. The 2020 FCPA Resource Guide emphasizes the importance of the CCO’s direct reporting line to the board and senior management status. The DOJ’s updated Corporate Enforcement Policy has further enhanced the prestige and role of the CCO, introducing key factors like the quality, experience, authority, independence, compensation, and reporting structure of the CCO. The episode also touches on the significance of the Delaware Court of Chancery’s decision in the McDonald’s case, which formalized the oversight duties of corporate officers, positioning the CCO as the second-most important role in an organization. Key takeaways include demonstrating real authority for the CCO, evaluating their professional qualifications, and assessing their actual status within your company.

Key highlights:

  • Key Inquiries Around the CCO and Compliance Function
  • Importance of CCO Certification and Court Decisions
  • Critical Takeaways for Compliance Professionals

Resources:

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

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 24 – Internal Reporting and Triage

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 24, we look into the critical internal reporting process and triaging of FCPA claims. As the CCO, you will oversee the initial steps when suspicious activities are reported. Jonathan Marks’ five-step process on early assessment of incoming information is explored, providing a structured approach for evaluating the severity of allegations from low-threat level to crisis management mode. Moreover, this episode emphasizes the necessity of effective hotlines, trained managers, and a culture of listening to employees to foster a safe reporting environment. Key takeaways include the DOJ and SEC’s emphasis on internal reporting lines, regularly testing hotlines, and the triage of claims to ensure appropriate investigation levels.

Key highlights:

  • Guidelines for Effective Compliance Programs
  • Jonathan Marks’ Five-Step Process for Early Assessment
  • Key Takeaways

Resources:

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

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Creativity and Compliance

Creativity and Compliance – Creative Approaches to Corporate Compliance with Tyson Avery

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.

Ronnie’s company, Learnings, and Entertainment, utilizes the entertainment devices people use to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible. In this episode of Creativity and Compliance, host Tom Fox and Ronnie Feldman are joined by Tyson Avery, the former Chief Ethics Compliance Officer at Starbucks and current Deputy General Counsel and Compliance Officer for Lucid Motors.

They discuss innovative strategies to make ethics and compliance engaging within organizations. Tyson shares insights into how he has leveraged creative methods to make serious compliance topics more relatable and accessible, emphasizing the importance of aligning corporate values with effective compliance programs.

One of the standout moments in the episode is Tyson’s recounting of the ‘Wally Awards,’ a unique initiative aimed at normalizing misconduct reporting and fostering a culture of transparency and trust. Through creative anonymization and employee engagement, the Wally Awards highlighted significant misconduct cases without compromising confidentiality, thereby encouraging ethical behavior across the company. The episode underscores the need for continuous, relatable, and engaging communications to embed compliance into the organizational culture.

Key highlights:

  • The Importance of Creativity in Compliance
  • Making Ethics Relatable
  • The Wally Awards: A Creative Compliance Initiative
  • Building Engagement and Trust
  • Advice for Implementing Creative Compliance

Resources:

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Blog

Top Compliance Leadership Skills for the Wild Wild West that is Coming – Part 3, Humor

This week, the world changed when Donald Trump was inaugurated as the 47th President of the US. Indeed, the only thing I can guarantee with complete certainty is change. I was therefore intrigued by Melissa Swift’s recent MIT Sloan Business Review article, “Three Nonnegotiable Leadership Skills for 2025.” In this week of change, I cannot think of a more prescient article for the compliance professional.

I adapted Swift’s three critical leadership skills for the compliance professional: fairness, curiosity, and a sense of humor. In this concluding blog post of this three-part series, I will explore how compliance leaders can develop and leverage these skills to strengthen their programs and inspire their teams throughout the tumultuous next four years using humor.

Your Saving Grace: Sense of Humor

As Ronnie Feldman continually reminds us, do not be “Debbie Downer,” or as I would say, do not be Dr. No from the Land of No. In some ways, Ronnie focuses on attitude, while I tend to focus a bit more on the message. However, you might look at it. Between audits, policy rollouts, regulatory updates, and managing the risk employees inevitably want to take, a sense of humor is a powerful tool for staying grounded and maintaining perspective.

It is important to note that you need the right kind of humor for compliance leadership. This does not mean you should become the office comedian. Instead, humor in compliance leadership is about finding light in challenging situations and encouraging your team to do the same. For example, after navigating a tough audit and telling your team, “Well, we survived—and I didn’t even need to bribe anyone with donuts this time!” That simple quip can diffuse tension and signal that it’s okay to exhale.

The humor in your attitude and what you can bring to your customer base. Humor can reduce stress. Compliance work often operates under tight deadlines, high stakes, and relentless scrutiny. This pressure can weigh heavily on teams, leading to burnout and diminishing productivity. A leader who uses humor to lighten the mood helps to ease stress, making the workplace feel less like a pressure cooker and more like a place of collaboration and problem-solving.

Humor can help to build relationships, as compliance leaders often face the challenge of appearing approachable while maintaining authority. Humor humanizes leaders, making them more relatable and easier to connect with. When you can laugh at yourself or acknowledge the absurdities of compliance work with a smile, your team feels more comfortable sharing ideas, asking questions, and raising concerns.

Humor can make you a better compliance officer. When people are less stressed, their creativity and problem-solving abilities improve. Humor reduces the brain’s fight-or-flight response, allowing for more thoughtful and innovative approaches to challenges. A leader who fosters an environment where it’s okay to laugh at setbacks or unexpected hurdles creates a culture where solutions flow more freely. For example, if a compliance initiative hits a snag, a leader who can frame it with humor, “Okay, so maybe this isn’t Plan A…or Plan B…but I have high hopes for Plan C!” encourages the team to stay flexible and keep brainstorming.

The Right Kind of Humor for Compliance Leadership 

Humor in compliance leadership is not about cracking jokes or becoming the office comedian. Instead, it is about using levity strategically to foster positivity and resilience. Some key principles are as follows:

  1. Diffuse Tension, Don’t Deflect Responsibility. A well-timed, self-deprecating comment can make you more relatable, but humor should never be used to deflect accountability. For example, if a compliance policy rollout faces delays, saying, “Looks like my time management skills could use some compliance training of their own!” shows humility without shirking responsibility.
  2. Celebrate Compliance Wins Playfully. Recognizing team achievements doesn’t have to be dry or overly formal. Use humor to make celebrations memorable. Consider giving out light-hearted awards like “Most Persistent Policy Enforcer” or decorating the office with “Mission Accomplished” banners after a successful audit. These small gestures show appreciation while keeping the mood light.
  3. Maintain Perspective. Compliance is serious work, but that does not mean you must take every situation or yourself too seriously. Laughing at the absurdities of navigating complex regulations or managing a mountain of policies reminds your team that, while the work is important, it’s okay to have a sense of humor about the challenges.

Applying Humor to Compliance Challenges in 2025

Humor is not simply a feel-good tool. It can be strategically applied to some of the most pressing challenges compliance professionals face in 2025.

  • Building Ethical Cultures Amid Workforce Discontent

With employee engagement at a low and workplace polarization on the rise, leaders must model fairness and transparency to rebuild trust. Humor can complement these efforts by making leaders more relatable and approachable. For example, during a town hall on compliance updates, opening with a light joke about the complexity of the latest regulations, “I think the word paid the lawyers who wrote this!” can put employees at ease and make the session more engaging.

  • Navigating Emerging Risks

As AI, ESG, and privacy dominate the compliance agenda, staying ahead of these risks requires proactive engagement and innovation. Humor can make daunting challenges feel more manageable. For example, when introducing training on AI ethics, a leader might quip, “Don’t worry, our goal is to make sure the robots are working for us, not the other way around!” This approach encourages curiosity and open-mindedness.

  • Managing Regulatory Fatigue

As regulations grow more complex, compliance fatigue becomes a real risk for teams. Or, as the Trump Administration whipsaws the business communities with new mandates morning, noon, and night, business and compliance leaders who inject humor into routine tasks, like creating a fun, interactive quiz for compliance training or adding light-hearted captions to a policy presentation, can make the work feel less monotonous. A leader who acknowledges the challenges with humor, such as “Regulatory updates: the gift that keeps on giving!” helps your compliance team feel seen and supported, even as they tackle challenging workloads.

How to Integrate Humor Into Your Leadership Style

If you’re ready to harness the power of humor in your compliance leadership, here are some practical tips:

  1. Know Your Audience. Tailor your humor to your team’s preferences and sensitivities. Avoid sarcasm or jokes that could be misinterpreted.
  2. Start Small. During meetings, test the waters with light-hearted comments or anecdotes. Observe how your team responds and adjust accordingly.
  3. Encourage Teamwide Levity. Create a culture where humor is welcomed. For example, designate a “fun committee” to plan occasional light-hearted activities, like a compliance trivia game or themed office decorations.
  4. Keep It Contextual. Use humor to enhance, not detract from, the seriousness of compliance work. Acknowledge the gravity of issues like regulatory violations while using humor to build resilience.

The Bottom Line: Humor as a Leadership Strength

In 2025, compliance leaders will face mounting challenges, from increasing regulatory complexity to employee disengagement to a more focused enforcement presence in some verticals. A sense of humor can be your secret weapon for gracefully and effectively navigating these difficulties.

By reducing stress, building connections, and fostering creative problem-solving, humor enhances your leadership and the overall resilience of your compliance team. Remember, humor doesn’t diminish the importance of your work; it underscores your ability to lead with empathy, perspective, and authenticity.

In the high-stakes world of compliance, laughter truly is a saving grace. So, the next time you find yourself knee-deep in regulatory updates or preparing for a strict audit, don’t forget to take a moment to smile, laugh, and remind your team that even in the most serious work, a little levity goes a long way.