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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 7 – Clawbacks and Holdbacks

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. 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, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. Today, on Day 7, we explore the critical insights from the DOJ Clawback and Holdback Program for compliance professionals.

Key highlights:

  • Integrating Compliance into Compensation
  • Financial Accountability Emphasis
  • DOJ’s Commitment to Individual Accountability
  • Continuous Evaluation and Improvement

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

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AI Today in 5

AI Today in 5: January 7, 2026, The AI Prescribing Meds in Utah Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to 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.

Top AI stories include:

  1. AI prescribing medicines in Utah. (ABC4 Utah)
  2. Compliance companies scaling AI. (CIO)
  3. The human factors reshaping AI-driven AML. (FinTech Global)
  4. Real-time AI for healthcare compliance. (HealthCare IT Today)
  5. AI reshaping VAT compliance. (Bloomberg)

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

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 6 – The M&A Safe Harbor Policy

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. 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, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. Today, on Day 6, we delve into the DOJ’s Mergers and Acquisitions (M&A) Safe Harbor Policy.

Key highlights:

  • DOJ Mergers and Acquisitions Safe Harbor Policy
  • Key Requirements and Deadlines
  • Historical Context and Clarifications

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 5 – Enhancing Compliance Through Automation

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. 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, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. Today, on Day 5, we explore how automation can revolutionize traditional compliance reporting, which is often manual, time-consuming, and error-prone. By leveraging data-driven solutions, compliance professionals can achieve near real-time reporting, improving decision-making and efficiency across their organizations.

Key highlights:

  • Challenges in Traditional Compliance Reporting
  • Integrating Tools for Real-Time Compliance
  • Balancing Real-Time Reporting with Data Security

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

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AI Today in 5

AI Today in 5: January 5, 2026, The Does The World Have Time Edition

Welcome to AI Today in 5, the newest edition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to 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.

Top AI stories include:

  1. Does the world have time to prepare for AI? (The Guardian)
  2. Colombia adopts an international standard for AI. (Global Compliance News)
  3. Client enablement with AI. (FinTechWeekly)
  4. Agentic AI rewriting rules for compliance. (Dallas Business Journal)
  5. Why AI Compliance needs to build operating systems. (Forbes)

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

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Blog

Why Every Company Needs a Corporate Relationships Policy

The Coldplay Concert and University of Michigan-Sherrone Moore imbroglios about consensual relationships introduced multiple issues for the compliance professional. While many saw them as romantic issues, others viewed them as corporate governance issues. Corporate compliance professionals spend a great deal of time talking about tone at the top, culture, and ethical leadership. Yet many organizations continue to ignore one of the most predictable sources of ethical failure, litigation exposure, and cultural rot: unmanaged workplace relationships.

Let me be clear at the outset. A corporate relationships policy is not about policing romance, friendship, or personal lives. It is about managing power, influence, and risk. If your organization has people, hierarchies, incentives, and decision-making authority, then you already have relationship risk. The only real question is whether you are managing it or pretending it does not exist.

The DOJ has been consistent on one point in the ECCP. Risks must be identified, assessed, and addressed in a way that reflects how the company actually operates. Relationships are part of how companies operate. Ignoring them is not cultural sensitivity. It is a governance failure.

Relationships Create Risk When Power Is Involved

Not all workplace relationships are problematic. The risk arises when one person can influence another’s pay, promotion, performance evaluation, assignments, or career trajectory. That is where favoritism, coercion, retaliation, and conflicts of interest live.

In enforcement actions, civil litigation, and internal investigations, I have seen the same fact pattern repeated again and again. A relationship is known. No controls are put in place. A complaint is made months or years after the incident. Suddenly, the organization is explaining to regulators, plaintiffs’ lawyers, and the board why it failed to act despite having notice. A corporate relationships policy forces the organization to confront a simple but uncomfortable truth: disclosure alone is meaningless unless it triggers action.

Disclosure Without Structure Is Theater

Many companies comfort themselves with a disclosure requirement that sounds reasonable on paper. Employees are told to disclose relationships, conflicts, or personal connections. After that, very little happens. From a compliance perspective, this is theater, not control.

A mature corporate relationships policy answers several follow-up questions, including “Then what?” and “Who reviews the disclosure?” ” How quickly must influence be removed? What interim controls apply? How is compliance documented and monitored?

Without these answers, disclosure becomes a liability. It creates notice without mitigation. Regulators do not reward that. Courts do not forgive it.

Culture Is Permanently Damaged When Employees Believe the System Is Rigged

One of the most corrosive effects of unmanaged relationships is the cultural one. Employees notice who gets promoted, who gets protected, and who gets opportunities. When relationships appear to trump merit, trust collapses.

This is where a corporate relationships policy becomes a culture document, not merely a legal one. A clear, consistently applied policy sends a powerful message: decisions will be made fairly, transparently, and without hidden influence. When employees believe the system is fair, they report concerns earlier, cooperate with investigations, and remain engaged. When they do not, they disengage or go external. Neither outcome is good for the organization.

Boards and Regulators Expect Speed, Not Intentions

Modern compliance is measured by response time and effectiveness, not good intentions. When a relationship presents a risk, the organization must act quickly to separate influence. That means changing reporting lines, removing decision authority, or imposing interim controls while structural changes are made.

A corporate relationships policy establishes clear timelines, ownership, and accountability. It gives managers a clock, not discretion. It provides a measurable compliance metric to report to the board. It gives the organization defensibility when regulators ask what happened and when it happened. The absence of such a policy almost guarantees inconsistent handling. Inconsistent handling almost guarantees enforcement risk.

This Is Not an HR Policy; instead, it’s a Governance Control

One of the most common mistakes companies make is treating relationships as purely an HR issue. That framing is outdated and dangerous. Relationships intersect with bribery risk, conflicts of interest, retaliation, and abuse of authority. Those are compliance and governance issues. A corporate relationships policy should be owned jointly by compliance, legal, and human resources, with board-level visibility. It should be integrated into investigations, promotions, succession planning, and risk assessments. Anything less is siloed thinking.

The Bottom Line

A corporate relationships policy does three things that every effective compliance program must do. They are:

  1. Identifies a risk that everyone knows exists but few want to name.
  2. Forces timely action instead of passive disclosure.
  3. Protects culture by reinforcing fairness and accountability.

If your organization does not have a clear, enforceable corporate relationships policy, you do not have a blind spot. You have a known vulnerability. And known vulnerabilities are exactly what regulators expect compliance professionals to address. That is not about being intrusive. It is about being responsible.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 4 – Building Effective Data Analytics Programs for Compliance

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. 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, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. On Day 4, this episode focuses on defining the specific risks an organization wants to monitor, capturing relevant data creatively, and leveraging internal expertise to build effective data analytics programs.

Key highlights:

  • Defining and Identifying Risks
  • Innovative Data Capture and Internal Collaboration
  • Demonstrating Value to Senior Management

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 2 – The ECCP on Incentives, Consequences, and Clawbacks

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. 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, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. Today, we look at what the ECCP has to say on incentives, consequences, and clawbacks.

Key highlights:

  • Starting with Incentives and Consequences
  • Incentive Program Breakdown
  • Consequence Management Deep Dive

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

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FCPA Compliance Report

FCPA Compliance Report-Episode 789 – Reinventing Compliance in 2026: Insights and Strategies with Daniel Zmak

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes, Daniel Zmak, Senior Director of Product Marketing at Diligent to discuss the evolving landscape of compliance.

They explore the importance of modernizing compliance practices, addressing challenges like fragmentation and fatigue, and leveraging AI and technology to enhance efficiency. Key topics include the compliance maturity journey, connected compliance, and strategies for improving governance and oversight. With actionable insights and practical advice, this session aims to guide compliance professionals through the dynamic changes in the field.

Highlights Include

  • Highs, Lows, and Surprises in Compliance
  • Compliance at an Inflection Point
  • The Compliance Maturity Journey
  • Fragmentation and Fatigue in Compliance
  • Connected Compliance: The Concept, Benefits and Future
  • AI in Compliance: Opportunities and Challenges
  • Dynamic Compliance Programs

Resources

Daniel Zmak on LinkedIn

Diligent Website

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Compliance Tip of the Day

Compliance Tip of the Day –Investigative Challenges

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.

This week we have considered issues relating to your internal investigations. Today we conclude with a review of some investigative challenges you may face.

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.