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Red Flags Rising

Red Flags Rising: S01 E32: Don’t Wait for Godot – Seize Control with Your Own Compliance Clarity

Mike & Brent draw inspiration from the current Broadway run of Waiting for Godot starring Keanu Reeves and Alex Winter to suggest some first principles of risk-based export controls compliance to trade compliance teams. They discuss the futility of the oft-reported sentiment in the trade compliance press of wanting more or clearer guidance from the U.S. government about export controls risk management is not necessary, because the guidance is already here and the “high probability” standard offers a path forward (01:03); how the “high probability” standard and a return to anti-diversion first principles is a way to avoid a repeat of the compliance whipsaw effect occasioned by the announcement, then suspension, of the Affiliates Rule (a/k/a the 50% Rule) (03:47); how an example of this is focusing on your compliance and enforcement risks under General Prohibition 10 and the inchoate provisions of U.S. export controls (07:10); how neither the Affiliates Rule’s adoption nor its suspension changed GP10 or the other anti-diversion regulations under U.S. export controls (12:03); why efforts to comply with the Affiliates Rule were not wasted (14:23); how to deal with and overcome “compliance fatigue” in organizations (16:04); Brent’s latest NYU PCCE post (17:59); and why there was an over-focus on item-based classifications relative to knowledge-based end-use and end-user catch-all provisions and GP10 (19:17).

They then conclude with a righteous installment of Brent Carlson’s “Managing Up” (21:36).

Resources:

“Waiting for Godot,” starring Keanu Reeves and Alex Winter, is currently playing at the Hudson Theater in New York City until January 4, 2026. For tickets, visit here.

Brent’s latest NYU Law School Program on Corporate Compliance & Enforcement post, from October 31, 2025

Brent’s email: brent@redflagsrising.com

Mike’s email: michael.huneke@morganlewis.com

Categories
Blog

Podcasting for Compliance Communications

If there is one truism from the practice of law that translates to the practice of compliance, it is that you are only limited by your own imagination. This holds in the 360-degree realm of communication in compliance, as communications obviously come in many forms. Many compliance practitioners well remember the 2012 Morgan Stanley declination. In this first declination made public, the DOJ recognized Morgan Stanley for emailing 35 compliance reminders to Garth Peterson over a seven-year period. Consider the power of 360-degree communications in the context of compliance reminders. Now imagine the power of short ethics and compliance video training clips being distributed over the same period and the effect it would have on both your employees and regulators.

Podcast Storytelling

Why not tell the story of the compliance program through a podcast? I call it podcast storytelling, and it can be a powerful tool. Each podcast series is a 5-part series and constitutes one story arc. The podcasts are about 10–15 minutes in length. The podcast-storytelling series can feature a variety of interviews led by a noted podcast host, such as the Voice of Compliance, yourself as the CCO, or other key individuals from your organization. It can be an interview with one or more people, or it can be a solo podcast.

While there would be a fully integrated storyline, each podcast and accompanying text would be stand-alone compliance training and communications that anyone at your organization could use. The podcasts can be distributed both internally and through your organization’s social media channels. There is a wide range of podcast sites available, including iTunes, Spotify, iHeartRadio, Google Podcasts, and Amazon. From each podcast, you can create multiple short audio clips or other forms of social media-sharing materials with key quotes and lessons learned that can be made as podcast cover art.

A series like this allows your organization not only to tell a story more effectively but also to reach a much larger audience than in any other format—live, audio-video, or in-person. Yet, there is another reason why you should consider this type of approach for compliance training and communications. It will provide you with the equivalent of market research and feedback. The number of listeners and downloads will provide a reliable source of data that you can use in other communications and training sessions.

Compliance Department Branded Podcasts

Want another option? How about a fully produced, branded podcast series for your internal compliance function? It could be two 25–30-minute episodes per month, with the guest selected by your compliance team. This format enables your corporate compliance function to tell the story of its greatest asset—its people—through interviews. Cannot get out of the country to travel? Still working remotely? Your branded podcasts offer a way to connect with your employees as we continue to navigate the aftermath of the COVID-19 pandemic. You can use the branded podcast to tell the story of compliance successes in your organization. You can also include other departments to share their accomplishments. As with the podcast storytelling series, it would be done collaboratively, working with your communications team.

Compliance News of the Day

Want to create concise and effective compliance communications? How about “Compliance News of the Day”? Have a daily curated news show featuring 3–4 compliance stories, accompanied by a summary of the series and its relevance to a compliance perspective for your organization. Make it fun so that your employees want to check in daily. When the DOJ comes knocking and asks how often you send out compliance communications, you can point to your Compliance News of the Day as a great starting point.

As a compliance practitioner, you should bring more storytelling into your compliance messaging, training, and communications. If you put the employee in the shoes of the person they’re watching, they will remember it because they will see how it applies to their own lives. Such training and communication experiences will last much longer than if you drone on over a written policy or show a PowerPoint slide. Marc Havener has described this storytelling as “expanding your classroom.” Ronnie Feldman calls it bringing memorable storytelling to your compliance communications and training.

Since you are only limited by your imagination in addressing compliance, why not use some of that imagination to be creative in your compliance training and communications?

Using Podcasts to Improve Corporate Culture

One of the biggest benefits of podcasting is that it allows a compliance function to connect with its audience on a more personal level. Unlike traditional forms of advertising, which often come across as impersonal and sales-driven, podcasts enable businesses to build a loyal following by offering valuable and engaging content. This can include interviews with industry experts, behind-the-scenes glimpses of the business, and informative discussions on relevant topics.

Now, apply the same concepts of audience engagement internally to an organization. What do you have? A mechanism to engage your employees, to engender trust, and to improve your overall corporate culture. Do you think this is a crazy way to improve culture? Consider all the advantages podcasting already offers. Podcasting is one of the most intimate forms of communication, and this concept holds for a corporate compliance podcast.

A major U.S. consumer product company launched a podcast featuring corporate executives. Who were the biggest fans of the podcast? It turned out it was the company employees, many of whom had never met their corporate executives. This allowed the executives to be humanized in a way no number of town hall meetings or other similar corporate events could ever achieve.

Categories
ACI FCPA Conference 2025

ACI-FCPA Conference Speaker Preview Series – Vince Walden on the Cutting Edge Use of Agentic AI for Compliance

In this episode of the ACI-FCPA and Global Anti-Corruption Conference Speaker Podcasts series, Vince Walden discusses his presentation at ACI’s Forum on AI and Data Analytics for Anti-Corruption Compliance, which will be held on Tuesday, December 2.

Some of the issues the panel will discuss are:

  • Agentic AI strategies for compliance;
  • The increased importance of data analytics in fraud prevention.
  • Cutting-edge AI strategies into 2026 and beyond.

I hope you can join me at the ACI–FCPA Conference. This year’s event will take place on December 3-4 at the Gaylord National Resort & Convention Center in National Harbor, Maryland, near Washington, D.C. The lineup of this year’s event is simply first-rate, featuring some of the top FCPA professionals, white-collar attorneys, and compliance practitioners in the field.

The 2025 program is being completely redesigned to help your organization stay agile, responsive, and ahead of the curve. Expect a dynamic agenda shaped by real-world priorities, practical takeaways, and the most cutting-edge thinking in compliance—led by a faculty of global practitioners with boots on the ground, encountering the very risks that come across your desk.

Please join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount by using the code D10-999-CPN26.

Categories
AI Today in 5

AI Today in 5: November 12, 2025, The FinCrime Frontier Edition

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

  1. Tech launches BA in AI. (WSMV4)
  2. Why AI in AML is the ‘FinCrime Frontier’. (AML Intelligence)
  3. Is explainable AI the missing link? (FinTech Global)
  4. Why humans must govern AI. (CCI)
  5. Compliance for AI agents. (Banking Exchage)

For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

Categories
Compliance Into the Weeds

Compliance into the Weeds: The Atlanta Hawks Scandal: Lessons in Financial Misconduct

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action.

The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity.

Key Highlights

  • Lessons from Atlanta Hawks Fraud Case
  • Least Privilege Access for Preventing Financial Fraud
  • Financial Data Examination for Fraud Detection
  • Executives’ Lavish Misconduct: Lessons in Ethics

Resources

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.

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Compliance Tip of the Day

Compliance Tip of the Day – Winnie the Pooh and Compliance Week-Eeyore and the Role of Corporate Legal

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

We continue our week of fun in compliance by looking at how Winnie the Pooh and his friends inform your compliance program. Today we review how Eeyore can show the CCO how corporate legal and compliance can work together.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing your Compliance Program, 6th edition which was recently released by LexisNexis. It is available here.

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Great Women in Compliance

Great Women in Compliance – Insights from ACI FCPA and Global Anti-Corruption Conference

In this episode of Great Women in Compliance, co-hosts Lisa Fine and Hemma Lomax get a special preview of the 42nd Annual ACI Conference on the FCPA and Global Anti-Corruption. They are joined by two of the conference’s distinguished speakers: Sandra Moser, Partner at Morgan, Lewis & Bockius and former Chief of the DOJ’s Fraud Section, and Kimberly Parker, Partner and Co-Chair of the White-Collar Defense & Investigations practice at WilmerHale.

Sandra and Kimberly share their personal journeys into the white-collar and compliance space, discuss why this conference is a “must-attend” event in the anti-corruption world, and dive deep into their upcoming session topics. Kimberly explores how companies are re-evaluating resource allocation as global priorities evolve, while Sandra tackles the critical compliance challenges of operating in China amid geopolitical tensions.

This episode is a must-listen for practical insights on shifting DOJ expectations, the future of compliance, and tips for any first-time attendees.

 Highlights include:

* Sandra and Kimberly’s Journeys to Compliance

* Spotlight on the ACI FCPA Conference:

* Evolving Priorities & Resource Allocation

* Navigating Compliance in China

* The Future of Compliance

Resources:  

ACI’s 42nd Annual Conference on the FCPA and Global Anti-Corruption (December, Washington, DC – https://www.americanconference.com/fcpa-dc/

* Morgan, Lewis & Bockius: https://www.morganlewis.com/bios/sandramoser

* WilmerHale: https://www.wilmerhale.com/en/people/kimberly-parker

Biographies

Sandra Moser is a corporate investigations authority and trial lawyer who co-leads the firm’s global white collar and investigations practice. She is former chief of the US Department of Justice’s (DOJ’s) Criminal Division, Fraud Section in Washington, DC, and a former Assistant US Attorney (AUSA) for the District of New Jersey. She defends companies, boards, and executives in a wide range of matters—including healthcare and federal program fraud, the False Claims Act (FCA), the Foreign Corrupt Practices Act (FCPA), securities, commodities, and anti-money laundering—involving the DOJ, state attorneys general offices, US Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), US Congress, and other domestic and international enforcement agencies.

Kimberly A. Parker’s practice focuses on white-collar criminal matters, internal corporate investigations, and compliance counseling. Ms. Parker is vice chair of the firm’s Litigation/Controversy Department, co-chair of the White Collar Defense and Investigations Practice, and co-leads the Foreign Corrupt Practices Act (FCPA) and Anti-Corruption Practice. Ms. Parker is also co-chair of the firm’s Pro Bono and Community Service Committee.

Ms. Parker represents clients in a range of criminal and enforcement matters and also provides compliance and governance advice. She has conducted internal investigations in the United States, Asia, Africa, Europe, and Latin America. She has represented companies and individuals in a variety of FCPA enforcement matters. She also regularly counsels clients facing difficult FCPA issues in a variety of business contexts, and assists clients in developing and implementing FCPA compliance programs and conducting FCPA training. She is a regular speaker at FCPA events.

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Compliance Tip of the Day

Compliance Tip of the Day – Winnie the Pooh and Compliance Week-Kanga, Roo and the Compliance Champion

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

We continue our week of fun in compliance by looking at how Winnie the Pooh and his friends inform your compliance program. Today, we consider how Kanga and Roo demonstrate the utility of compliance champions throughout your organization.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing your Compliance Program, 6th edition which was recently released by LexisNexis. It is available here.

Categories
Blog

The 5 Blueprints for a Compliance Podcast

In the corporate world, few tools are as powerful as the spoken word. Podcasts have become not only a medium of storytelling but a mechanism for influence, education, and relationship-building. For compliance professionals, a podcast can do far more than share updates on the latest DOJ guidance or FCPA enforcement. They can shape culture, inspire ethical leadership, and build lasting connections across the compliance ecosystem. Megan Dougherty, in her seminal book “Podcasting for Business,” laid out five business podcast blueprints. I have adapted her work for a compliance professional, explaining why you should start an internal podcast for your employees on compliance.

Drawing from Dougherty’s The Business Podcast Blueprints, we can identify five core podcast strategies that directly translate to the compliance profession: Relationship Building, Audience Engagement, Thought Leadership, Conversion, and Content. Each blueprint offers a unique path for compliance communicators. These are all critical, whether you are educating employees, influencing senior management, or amplifying the compliance message across your industry.

Let’s explore how each blueprint can help you create a compliance podcast that not only informs but transforms.

1. Relationship Building: Turning Conversations into Compliance Connections

Every effective compliance program begins with strong relationships among compliance officers, business units, leadership, employees, and the organization’s regulators. A Relationship Building podcast mirrors that principle. These shows rely on interviews and dialogues designed to create genuine professional bonds. For compliance professionals, this may mean inviting general counsel, audit leads, HR heads, or even regulators to discuss how they envision ethics and compliance evolving in their respective domains.

Instead of focusing on legal jargon, the host becomes the facilitator of understanding. The show notes and promotions should highlight the guest’s insights, emphasizing shared goals and mutual respect. The relationship is the reward. Investment in this model should focus on enhancing the guest experience through thoughtful questions, warm follow-ups, and even small gestures of appreciation. In essence, your podcast becomes an extension of your compliance diplomacy—building bridges before you need to cross them.

2. Audience Engagement: Educating, Empowering, and Evolving Your Compliance Community

If your compliance podcast already has a defined internal or external audience, such as employees across global subsidiaries or a community of compliance peers, then an Audience Engagement podcast is your vehicle for connection. This format thrives on flexibility. You can host Q&A sessions on compliance dilemmas submitted anonymously by employees, share brief educational “compliance tips,” or conduct interviews with experts on specialized risks, such as data privacy or sanctions compliance. What makes this model powerful for compliance is its two-way nature. Audience Engagement podcasts invite feedback, discussion, and participation. They allow you to hear the “compliance pulse” of your organization.

For show notes, focus on actionable takeaways: steps, checklists, and reflection prompts. This is also the ideal blueprint for sponsorship if those sponsors align with your mission. For instance, an ethics-tech vendor or compliance training platform might co-sponsor an educational episode. Your investment priority? High production value and multi-format distribution. A compliance podcast becomes truly valuable when the same episode can be transcribed for newsletters, summarized for LinkedIn, and clipped for internal training. In this way, Audience Engagement podcasts move compliance from “check the box” to “join the conversation.”

3. Thought Leadership: Becoming the Voice of Compliance

If Relationship Building is about who you know, then Thought Leadership is about what you stand for. This is the blueprint that transforms a compliance officer into a recognized industry authority. A Thought Leadership podcast emphasizes ideas, analysis, and influence. These shows often blend solo commentary with expert dialogues. Think of it as a weekly masterclass on governance, ethics, and risk. It is your chance to interpret trends, dissect new regulations, and challenge the status quo.

Show notes should highlight key ideas and next steps, turning insight into implementation. In a world where the DOJ’s Evaluation of Corporate Compliance Programs (ECCP) evolves annually, a compliance Thought Leadership podcast keeps your organization ahead of the curve. This is also where you invest in top-tier audio and post-production. Crisp sound and professional editing convey credibility. The same principle applies in compliance: presentation reflects integrity. By consistently producing thoughtful, well-researched episodes, you elevate your company’s brand while modeling what ethical leadership sounds like.

4. Conversion: Moving from Awareness to Action

In compliance, we often talk about buy-in. A Conversion podcast achieves precisely that: it turns awareness into action, engagement into enrollment. This blueprint aligns perfectly with the internal marketing of a compliance program. For instance, you might produce a limited series leading up to Corporate Compliance and Ethics Week, encouraging employees to sign up for training or submit compliance questions. Alternatively, external consultants can use a Conversion podcast to build trust with prospective clients by featuring successful case studies and compliance transformations.

Here, a case-study-style interviews work beautifully. Think of an episode featuring a supply-chain leader who revamped due diligence using new analytics tools, or a CCO who implemented an effective third-party risk program. Each story demonstrates value and calls the listener to act: “Here’s what we did. You can too.” No outside sponsors are needed in this model. The “product” is your compliance initiative. The goal is measurable engagement, as evidenced by increased training completions, a stronger reporting culture, or higher attendance at ethics town halls. A Conversion podcast is, in many ways, compliance communication at its most strategic. It moves your audience along the maturity curve from awareness to advocacy.

5. Content: Building a Compliance Knowledge Engine

Finally, we reach the Content podcast, which is the Swiss Army knife of the blueprints. Every compliance communicator needs one, whether it stands alone or supports your other podcast strategies. A Content podcast is designed for repurposing. Every episode becomes a cornerstone for articles, blog posts, training clips, and internal briefings. For compliance professionals, this is a dream model: every 20-minute conversation with a subject-matter expert can be transcribed into policy guidance, an internal newsletter feature, or even a white paper.

Show notes here should be as detailed as possible. Here, you can think of them as a searchable compliance archive. Want to create a “Compliance 365” campaign? Your Content podcast provides the raw material. The main investment should go into formatting and distribution. Use transcripts, video snippets, and visual infographics to meet your audience where they are, whether in the boardroom, on the factory floor, or scrolling LinkedIn during lunch. A Content podcast ensures that your compliance message doesn’t end when the mic goes off. It endures across formats, reinforcing the culture of ethics you’re working to establish.

Pulling It All Together: The Compliance Podcast as a Strategic Asset

So which blueprint should you choose? The answer, as in compliance itself, depends on your goals. If your goal is to build alliances within the business, focus on Relationship Building. To foster ongoing dialogue, select Audience Engagement. To elevate your professional reputation and set the tone for the field, lead with Thought Leadership. When you need to move your stakeholders toward action, lean into Conversion. And if your goal is sustainability and scalability, Content will power your entire ecosystem.

The best compliance podcasts blend these blueprints. A single series might start with Relationship Building and a Chief Audit Executive, evolve into Thought Leadership commentary, and conclude with a Conversion-style call to action for employees to “Speak Up.” The beauty of podcasting for compliance professionals lies in its adaptability. It is not merely a medium, but rather it is a method of leadership.

A compliance podcast is not just another communication channel; it is a strategic platform that amplifies trust, transparency, and accountability. When done right, it embodies the very principles we champion as compliance professionals.

Before you hit “record,” ask yourself: What is my blueprint? Because when your voice carries purpose and your podcast carries integrity. Remember, you are not just broadcasting; you are also engaging. You are building the next generation of compliance culture.

For a free eCopy of Megan’s book, Podcasting for Business, click here.

Categories
ACI FCPA Conference 2025

ACI-FCPA Conference Speaker Preview Series – Anik Shah on Lawyering Through These Uncertain Times

In this episode of the ACI-FCPA and Global Anti-Corruption Conference Speaker Podcasts series, Anik Shah discusses his panel at the event, “Lawyering Through Uncertainty: The New Reality of Advising Clients and Making Decisions in Unchartered Territory.”

Some of the issues the panel will discuss are:

  • Navigating current client dilemmas;
  • Risk Assessments and Internal Investigations;
  • Recalibrating your compliance program for 2026 and beyond.

I hope you can join me at the ACI–FCPA Conference. This year’s event will take place on December 3-4 at the Gaylord National Resort & Convention Center in National Harbor, Maryland, near Washington, D.C. The lineup of this year’s event is simply first-rate, featuring some of the top FCPA professionals, white-collar attorneys, and compliance practitioners in the field.

The 2025 program is being completely redesigned to help your organization stay agile, responsive, and ahead of the curve. Expect a dynamic agenda shaped by real-world priorities, practical takeaways, and the most cutting-edge thinking in compliance—led by a faculty of global practitioners with boots on the ground, encountering the very risks that come across your desk.

Please join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount by using the code D10-999-CPN26.