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ACI FCPA Conference 2025

ACI-FCPA Conference Speaker Preview Series – Dan Kahn on the New DOJ Enforcement Priorities

In this episode of the ACI-FCPA and Global Anti-Corruption Conference Speaker Podcasts series, Dan Kahn discusses his panel at the event, “Unpacking the DOJ’s New FCPA Enforcement Guidelines and Priorities: Practical Takeaways for Updating Risk Management, Internal Investigations, and Compliance Strategies.”

Some of the issues the panel will discuss are:

  • How does the current DOJ guidance inform compliance?
  • How to recalibrate your compliance program based on the updated Guidance.
  • What does the DOJ FCPA Guidance say about enforcement priorities? 

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.

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Compliance Tip of the Day

Compliance Tip of the Day – Business Rationale in the 3rd Party Risk Management Process

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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.

This week, we are reviewing the third-party risk management process. Today, we take up the Business Rationale.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Innovation in Compliance

Innovation in Compliance – Navigating the Future of Supply Chain Compliance with Travis Miller

Innovation is present in many areas, and compliance professionals must not only be prepared for it but also actively embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom welcomes Travis Miller, Chief Strategy Officer and General Counsel at Source Intelligence, to discuss major developments in supply chain compliance.

Miller outlines his recent job transition from Google, where he was the Head of Supply Chain Compliance and Social Responsibility. He delves into the complexities and innovations of Source Intelligence, a company focused on supply chain transparency and compliance. He also talks about his book ‘Guide to Supply Chain Compliance Laws and Regulations’ and highlights the growing significance of supply chain mapping due to new regulations. The conversation examines the pivotal roles of data accuracy, supplier collaboration, and AI in enhancing supply chain compliance. Miller predicts a more technical and relationship-driven future for supply chain professionals, stressing the importance of strategic partnerships. The discussion also explores four market realities that companies can’t ignore, emphasizing the pitfalls of outdated metrics and manual processes. Finally, Travis shares his insights on balancing automation with human judgment to optimize compliance operations.

Key highlights:

  • The Importance of Supply Chain Compliance
  • Supply Chain Mapping and Regulations
  • Full Material Declarations and Their Significance
  • AI in Supply Chain Compliance
  • The Future Role of Supply Chain Professionals
  • The Compliance Playbook and Market Realities

Resources:

Travis Miller on LinkedIn

‘Guide to Supply Chain Compliance Laws and Regulations

The Compliance Playbook is Broken on LinkedIn

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

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Compliance Tip of the Day

Compliance Tip of the Day – The Third-Party Risk Management Process

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with concise, actionable tips to help you stay ahead in your compliance efforts. 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.

This week, we will review the third-party risk management process. Today, we outline the process and explain how to implement it.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Compliance Tip of the Day

Compliance Tip of the Day – Winnie the Pooh and Compliance Week – Winnie the Pooh as CECO (Think, Think, Think)

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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 conclude our week of fun in compliance by looking at how Winnie the Pooh and his friends inform your compliance program. Today, we reflect on lessons from Winnie the Pooh for the CECO.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Blog

Listen Up: Why Voice – Driven Storytelling Is Compliance’s Most Underused Tool

In the modern corporate environment, we face a paradox: we have never had more tools to communicate, yet employees have never felt more overwhelmed by the sheer volume of communication. Emails drown in inboxes. Slide decks gather dust. Policy updates are skimmed at best and ignored at worst. For compliance officers trying to connect with a global workforce, the problem is not merely volume; rather, it is attention, trust, and retention.

That is where audio communications comes into play. Increasingly, forward-leaning companies are turning to voice-driven communication, which includes short audio messages, internal podcasts, and narrative voice notes, as a powerful way to reach employees where they are. And if you’re not already leveraging the human voice as part of your compliance toolkit, you are missing a deeply effective channel hiding in plain sight.

Because voice is not just another medium; voice is human. Voice conveys credibility, vulnerability, and intention. Voice cuts through noise in ways no written communication can match. And for compliance programs striving to build cultures of ethics and accountability, that authenticity is invaluable.

This makes it an ideal tool for compliance professionals to use in their communications. You can use it in long-form podcasts or short, bite-sized espresso shots of compliance.

Why Voice Still Wins in a Digitized World

Every compliance officer knows that trust is the currency of influence. Trust is built not only through facts but also through perceived sincerity. When employees hear a leader’s voice, it is unpolished, direct, and unfiltered. Corporate employees react differently when listening to a sanitized corporate memo than when reading it.

Tone becomes a tool. Cadence becomes emphasized. A pause invites reflection. A shift in pitch signals seriousness or warmth. These cues are often overlooked in text but are essential when navigating complex ethical issues, gray areas, and behavioral expectations. Voice also supports what I call the narrative advantage. Humans remember stories far better than bullet points. An audio message with a real-world dilemma—“Let me tell you about a call I got last Friday…”—lands with more impact than a list of rules ever will. For compliance, where the goal is not mere knowledge but behavioral change, this is rocket fuel.

Five High-Impact Voice Formats for Compliance Leaders

You do not need an internal studio or a communications team to use voice effectively. You need structure, intention, and consistency. Here are five proven formats I encourage compliance professionals to adopt:

1. Two-Minute Ethics Drops

A weekly, two-minute audio memo from the CCO or another senior leader can reshape how employees perceive compliance. These are not policy recitations. They are reminders, insights, or reflections on real events, brief enough to consume during a commute, meaningful enough to spark thought. Imagine this as the compliance equivalent of a coach’s pre-game talk.

2. Manager Voice Notes

Compliance does not scale unless managers become compliance multipliers. Provide managers with scripts or talking points, and then ask them to record brief voice notes for their teams. Local leaders speaking in their own words create a sense of intimacy and authenticity. People listen differently when the speaker is their direct leader, rather than a representative from headquarters.

3. Decision Diaries

These short, story-based audio segments illustrate how hard decisions are made inside the organization. They highlight the tension between competing priorities—sales versus safety, growth versus due diligence, and speed versus accuracy—and guide employees through the reasoning process. Employees learn not only what decision was made, but also why it was made.

4. Speak-Up Spotlights

One of the most underutilized voice tools is the anonymized “speak-up journey” segment. These episodes take listeners inside the lifecycle of a report without revealing identities. This builds trust in the system, demystifies investigations, and demonstrates action. It is one of the fastest ways to strengthen your speak-up culture.

5. The Board-Level Fireside

A quarterly voice conversation between the CCO and board chair (or audit committee lead) is incredibly powerful. Hearing the board speak directly to employees about ethics and risk sends a crystal-clear message: this topic matters at the highest levels. This is tone-from-the-top in its purest form.

How to Craft Voice Messages That Actually Land

There is an art and a discipline to creating voice content that resonates and drives behavior. Based on what I’ve seen across leading compliance programs worldwide, here are the five principles that matter most.

Lead with humanity, not rules.

Start with a lived moment or recognizable scenario. “I got a call last week that stopped me cold…” is a more effective opening than “According to Policy 3.4.”

Use language meant for the ear.

Short sentences. Natural phrasing. Conversational tone. You are having a hallway conversation, not reading a legal memo.

Deliver one idea per recording.

If your message attempts to cover five policies, employees will remember none of them. Focus on a single behavior change or risk awareness point.

Tie every story to a specific action.

Compliance storytelling without a call to action is entertainment. You want transformation.

Examples:

  • “If you see a third party offering to ‘open doors,’ log it today.”
  • “If a customer requests data access, use the Data Transfer Checklist before responding.”

Close with a choice

End with clarity: “If X happens, do Y by Z.” Employees appreciate explicit guidance. Regulators notice it too.

Measuring Impact: Voice Is Still Data

Even though voice feels personal and human-centered, it does not escape measurement. In fact, the metrics are straightforward and incredibly useful:

  • Reach—How many employees pressed play?
  • Completion—Do people listen past the first minute?
  • Reflections—Capture a one-question pulse: “What would you do now? ”
  • Action proxies—Did advisory requests or help tickets increase after the episode?

When we combine voice with smart analytics, we get a clear picture of engagement and behavioral shifts. This turns compliance storytelling into compliance intelligence.

Governance, Structure, and Safety

Voice communication must be treated like any other formal compliance communication channel. That means:

  • Pre-clearance of scripts with Legal and HR
  • Transcripts stored in your compliance file system
  • Tagging episodes to policy numbers and risk areas
  • Version control
  • Localization using local leaders, not HQ dubbing

Done right, voice enhances governance. Done poorly, it creates unnecessary risk. The good news? A solid process solves that problem.

The Fastest Path to Launch: A Ready-Made Starter Kit

If you want to bring voice storytelling into your program quickly, here’s a simple template:

Series title: Choices We Make

Cadence: Weekly, two minutes

Structure:

  • Hook (10 sec)
  • Context (30 sec)
  • Dilemma (30 sec)
  • Decision (30 sec)
  • Outcome (20 sec)
  • Call to action (20 sec)

Three great starter topics for your first episodes:

  1. A conflict of interest dilemma
  2. A third-party red flag escalation
  3. A speak-up report that led to a positive safety change

This is the simplest, fastest, and lowest-cost compliance communication upgrade you can implement.

Closing Thoughts: The Future of Compliance Is Human

We talk endlessly about systems, controls, and technology, and all of those matter. However, at the end of the day, compliance remains a human discipline. It relies on trust, judgment, empathy, and courage—written policies guide. Training informs. If you want your workforce to act with integrity when no one is watching, they need to hear your voice when it matters. Now is the moment to step behind the microphone. Audio connects, but more importantly, voice connects.

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Compliance Tip of the Day

Compliance Tip of the Day – Winnie the Pooh and Compliance Week – Piglet, the CFO and Compliance

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with concise, actionable tips to help you stay ahead in your compliance efforts. 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 Piglet and how the role of the CFO informs your compliance program.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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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.

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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.