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Compliance Tip of the Day

Compliance Tip of the Day – Leading from the Inside Out

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, we aim to provide 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.

Today, we discuss why a human-centric approach to leadership has become necessary, not just an aspiration for compliance executives.

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Compliance Tip of the Day

Compliance Tip of the Day – Clarifying Compliance Mandates

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, we aim to provide 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.

Today, we examine the cornerstone of compliance success: understanding the mandates, explicit or implicit, handed down by your stakeholders.

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Blog

Compliance Leadership Week: Clarifying Compliance Mandates

We continue our exploration of compliance leadership through the article Warning: Upgrade your personal operating model by McKinsey authors Arne Gast and Suchita Prasad. Today, we look at leadership as a compliance function within the corporate corpus. In Part 2 of our exploration of the article, we consider compliance mandates and what they mean for compliance in this tumultuous year of 2025.

As compliance professionals, our responsibilities often revolve around understanding and executing mandates clearly articulated by regulators, boards, and senior management. But how frequently do we step back and reflect deeply on whether we genuinely grasp the nuances of these mandates, especially in moments of high-stakes transformations? The effectiveness of your compliance program depends greatly on your ability to understand and balance stakeholder expectations, prepare strategically for critical leadership conversations, and decisively simplify your priorities.

Fully Understanding Your Compliance Mandates

The cornerstone of compliance success lies in deeply understanding your stakeholders’ mandates, explicit or implicit. Internal stakeholders, such as your board of directors, senior executives, and various employee groups, set mandates that reflect the organization’s culture, risk appetite, and strategic direction. Meanwhile, external stakeholders, including regulators, investors, customers, suppliers, and advocacy groups, shape mandates by articulating compliance expectations clearly through regulations, industry standards, or advocacy initiatives.

Begin by identifying your key stakeholders. Who can influence your compliance activities, and who is directly affected by the outcomes? Then, consider whether you have fully captured their expectations and priorities. It is critical to discern their minimum thresholds for compliance performance and their maximum aspirations.

Experience indicates that compliance leaders often avoid ambitious targets due to apprehension about potential opposition. However, leaders must embrace ambitious goals and manage expectations thoughtfully to drive meaningful compliance change. Harvard scholars Ronald Heifetz and Marty Linsky highlight that leadership often involves “disappointing your people at a rate they can absorb.” Compliance leadership is no different.

Consider the example of a new CEO at an Asian telecommunications firm widely known for its harmonious workplace culture. Initially, he hesitated to pivot toward a performance-driven compliance culture, worrying he would disrupt cherished organizational traditions. However, after meaningful conversations with his leadership team and employees, it became clear that the cultural shift was overdue and broadly expected. Recognizing this explicit mandate empowered him to move decisively, driving the compliance culture transformation the organization needed.

Preparing for Your Critical Compliance Leadership Conversations

As compliance professionals, we know that executing effective compliance frameworks doesn’t solely rely on intricate diagrams, complex spreadsheets, or dense policies. Instead, compliance culture grows from critical conversations. Whether they’re one-on-one meetings addressing specific compliance concerns, more extensive group dialogues about emerging risks, or formal regulatory reviews and hearings, the narrative you establish and sustain across these discussions defines compliance success.

Start your planning by identifying the five or ten most critical compliance conversations you anticipate in the coming months, and these are your “moments of truth.” Define explicitly what you hope participants will feel, understand, and commit to after each interaction. Clarify the outcomes that represent success versus those indicative of mere mediocrity or outright failure. And importantly, consider how these conversations weave together over time, collectively driving the larger compliance narrative forward.

During a business turnaround, one European retail CEO mapped out ten moments of truth over three months. Her leadership team meticulously crafted scripts and messaging, preparing carefully for possible setbacks, assigning clear roles, and ensuring smooth transitions between discussions. Treating the conversations as linked scenes in a cohesive movie enabled her to lead effectively and deliver impactful change. Compliance leaders can adopt similar meticulousness to foster clear, compelling compliance narratives.

Prioritize by Simplifying: What Can You Quit Doing Now?

Compliance roles are notoriously complex, and practitioners often find themselves mired in endless initiatives, overlapping responsibilities, and underperforming projects. While traditional advice, hard work, persistence, and extensive hours are helpful, they overlook the importance of strategic selectivity. Knowing what to stop doing is as critical as deciding what to pursue.

Evaluate your current compliance initiatives candidly. Identify lower-impact activities consuming disproportionate resources. Compliance departments frequently carry legacy programs or processes out of habit or inertia. Challenge yourself and your team by asking tough questions: Can you scale from multiple “must-win” compliance battles to fewer, high-impact engagements? Are there pet projects consuming attention without delivering measurable compliance value?

The story of a new CEO in the toy industry vividly illustrates this principle. Inheriting an organization historically focused on expansive growth, she quickly realized her mandate was to streamline and improve profitability. Despite her passion for growth and innovation, she strategically withdrew from unnecessary meetings and halted initiatives outside critical compliance and operational frameworks. She freed essential bandwidth by explicitly quitting these peripheral engagements, allowing her team to prioritize and execute tasks directly tied to profitability and compliance improvement.

A Focused Approach: Rocks, Not Pebbles

Leadership effectiveness amplifies when focusing energies on areas where your unique talents create maximum impact. Compliance leaders, facing myriad responsibilities, should take a page from McKinsey’s research, underscoring the importance of prioritizing tasks uniquely suited to their strengths.

Consider carefully which compliance projects truly require your direct involvement, end-to-end oversight, or visible engagement. Recognize those initiatives where your expertise uniquely influences outcomes, be it establishing new compliance cultures, managing strategic regulatory engagements, or steering high-stakes investigations.

Leverage your team effectively, clarifying your expectations explicitly around roles, outcomes, risks, and the precise nature of your support. This clear delegation empowers your compliance organization to achieve greater effectiveness while building future compliance leadership strength.

Who’s Supporting Your Compliance Efforts?

Lastly, compliance leaders require strong, proactive support teams, assistants, or chiefs of staff who prioritize your time, anticipate compliance demands, and help sustain your professional effectiveness. Periodic changes to these roles can break ineffective patterns and optimize your ability to manage compliance responsibilities sustainably and productively.

In a high-pressure services industry role, a senior leader switched assistants to overhaul his professional rhythm radically, prioritizing essential compliance tasks, global engagements, and personal wellness. The new assistant actively understood his work deeply, prioritized exercise and health routines, and proactively managed compliance demands. This thoughtful approach markedly boosted the leader’s productivity, sustainability, and compliance impact.

Compliance success hinges significantly on understanding your mandates thoroughly, preparing meticulously for key conversations, simplifying priorities strategically, and leveraging your unique strengths. Regularly reassess stakeholder expectations, communicate transparently, and focus on impactful compliance actions. By embracing these disciplined approaches, compliance professionals can lead their organizations confidently through the complexity and change inherent in modern business environments.

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Compliance Tip of the Day

Compliance Tip of the Day – A Personal Operating System for Compliance Professionals

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, we aim to provide 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.

Today we look at the importance of a personal operating model for compliance officers.

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Daily Compliance News

Daily Compliance News: March 24, 2025, The ABC Task Force 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 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:

  • UK, France, and Switzerland launch the ABC task force. (WSJ)
  • How resilient is your power supply? (BBC)
  • China targets ‘petty’ corruption. (WSJ)
  • Is the Former Argentinian President banned from the US for corruption? (Buenos Aires Times)
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Blog

Compliance Leadership Week: A Personal Operating System for Compliance Professionals

This week, we begin a five-part exploration of leadership for compliance professionals. All of this week’s blog posts will be based on articles from McKinsey & Company, and all authors are with McKinsey. I will look at individual leadership issues, compliance team leadership issues, and issues for a Chief Compliance Officer (CCO) or compliance professional for greater corporate matters. We begin our exploration by considering individual leadership issues for compliance professionals. Today’s (and tomorrow’s) blog posts are based on the article Warning: Upgrade your personal operating model by McKinsey authors Arne Gast and Suchita Prasad.

Compliance professionals are used to alerts and notifications reminding us to keep our organizational technology and systems up-to-date. Messages like “Update now or risk losing access” flash across our screens regularly, prompting immediate action to secure organizational infrastructure. But how often do we take such vigilant measures to update our personal operating systems and the personal models that guide our professional effectiveness and impact?

In today’s rapidly evolving corporate landscape, compliance officers face unprecedented challenges. Regulatory shifts, technological advancements, new business risks, and societal expectations are constantly in flux. To navigate these waves successfully, we must regularly revisit and recalibrate our personal operating models. Like any critical business system, your personal operating model comprises the choices you make regarding your priorities, the roles you fulfill, the allocation of your time, and the management of your energy.

The Importance of a Personal Operating Model for Compliance Officers

Just as outdated technology poses security risks to an organization, an outdated personal operating model can compromise your effectiveness as a compliance officer. Regularly updating your approach helps ensure alignment with organizational goals, regulatory demands, and professional growth opportunities. Yet, unlike device upgrades, no automatic alerts prompt these updates; compliance officers must generate internal notifications for reflection and action.

The Four Drivers of Your Personal Operating Model

To effectively refresh your compliance operating system, consider four critical drivers: priorities, roles, time, and energy. Each element is essential to your professional impact and resilience.

1. Priorities

Compliance leadership starts with setting clear, strategic priorities. Have you identified your compliance mandates? Do you understand the expectations and potential areas of overshooting or underperformance? Compliance mandates come from various stakeholders, including senior executives, board members, regulatory bodies, and external auditors. Clarifying these mandates and transparently communicating them is vital. Leaders must boldly determine which mandates to fulfill, manage stakeholder expectations, and consciously decide where strategic disappointments might be necessary, always within manageable bounds.

Consider a compliance officer entering a new organization. Initially hesitant to make sweeping changes to established protocols, a careful stakeholder review might reveal a clear mandate for significant compliance transformation. Recognizing and embracing these mandates positions you to effectively lead impactful change.

2. Roles

Effective compliance officers clearly define roles, prioritizing tasks uniquely suited to their capabilities and delegating responsibilities to leverage organizational strength effectively. Are you focusing only on critical compliance tasks that you can manage effectively? Are you building positive leverage by engaging competent team members?

For instance, overseeing critical internal investigations might require direct involvement, while day-to-day compliance monitoring could be delegated to well-trained compliance staff. Choosing where to apply your expertise maximizes your overall impact and builds robust organizational compliance capabilities.

3. Time

Managing time is a fundamental skill for compliance leaders. How effectively are you scheduling and structuring your time to handle critical compliance issues proactively rather than reactively? Establishing boundaries, creating productive rhythms, and thoughtfully redesigning meetings can dramatically increase compliance effectiveness.

For example, compliance executives often experience calendar overload with meetings, training sessions, and urgent crisis interventions. Reflecting on your meeting structure can streamline effectiveness, eliminate unnecessary gatherings, and improve the productivity and clarity of compliance communications. Clearer schedules allow space to manage emerging compliance risks and regulatory changes proactively.

4. Energy

Finally, maintaining and protecting your energy is crucial for sustained effectiveness and resilience. Compliance roles are demanding and often filled with high-pressure situations and complex problem-solving. Do you actively manage your health, nurture supportive relationships, and connect deeply with the purpose behind your compliance work?

A compliance leader in a multinational firm found himself stretched thin by constant international travel and demanding audits. Realizing his health was compromised, he committed to regular exercise, improved nutrition, and better sleep habits. Coupled with meaningful social connections and reflection on his professional purpose, these actions revitalized his energy, enhanced productivity, and deepened his commitment to his compliance leadership role.

Implementing Your Personal Operating System Upgrade

To systematically update your personal compliance operating model, consider enlisting accountability partners, colleagues, mentors, or trusted personal contacts—to ensure consistent reflection and action. Regularly scheduled reviews, akin to software updates, help maintain your personal operating system’s integrity and effectiveness.

As compliance officers, our effectiveness hinges significantly on our ability to adapt and respond proactively to evolving regulatory and business landscapes. While technology alerts remind us to upgrade our devices, we must generate our notifications, prompting essential personal model upgrades. Continually recalibrating priorities, clearly defining roles, efficiently managing time, and actively preserving our energy empower us to deliver impactful compliance leadership.

Maintaining an up-to-date personal operating model positions compliance professionals to proactively anticipate risks, effectively drive organizational compliance initiatives, and sustain long-term professional resilience. Regular updates to your personal compliance operating system are not merely beneficial; they are essential to your continued success and the broader success of your organization.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 48 – The March Madness Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

Stories this week include:

  • Severance, your ‘Innie” and work-life balance. (NYT)
  • Difference in work generations. (HR Exchange)
  • Treasury flags $200 transactions at the border. (WSJ)
  • Schwartz fires Paul Weiss. (Law360)
  • Huawei bribery scandal hits EU. (BBC)
  • EU Omnibus Package: 10 things you should know about the proposed changes to key sustainability legislation (White Case)
  • Half of Compliance Officers Have Anxiety; Their Org Chart Might Be the Culprit (CCI)
  • Compliance Programs and Leaks (Radical Compliance)
  • Job Seekers Hit Wall of Salary Deflation (WSJ)
  • Florida police horse nabs man after wild chase over drug deal | ‘Get that bad man! ‘ (Fox 35 Orlando)

 

Resources:

Kristy Grant-Hart on LinkedIn

Prove Your Worth

Tom

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Blog

Compliance and the Audit Committee in the Age of Trump

In my many years evangelizing the virtues of compliance, I have often discussed how the compliance profession thrives on predictability and clarity. However, the recent whirlwind of policy initiatives from the Trump administration presents corporate compliance professionals, particularly audit committees, with unprecedented oversight pressures and challenges. More than ever, audit committees must demonstrate agility, vigilance, and a robust commitment to compliance principles amidst rapid and unpredictable policy shifts.

Fortunately, our colleagues Michael W. Peregrine and Ashley Hoff from McDermott Will & Emery LLP have recently released a paper on this topic entitled Audit Committees Face Significant New Compliance Oversight Pressures. Every Chief Compliance Officer (CCO), Board member, and Audit or Compliance Committee member must read and study their paper as they list multiple lessons learned from this evolving landscape under this second Trump Administration. I have used the author’s thoughts as a framework that a corporate compliance function can use to work with an audit committee to navigate the chaos.

1. Embrace Agility in Compliance Management

The Trump administration’s “flood the zone strategy illustrates vividly that agility is no longer optional; it is now imperative for business. Compliance professionals must swiftly adapt to shifting regulatory priorities, ensuring their compliance programs can pivot quickly. Practically speaking, your compliance framework must include flexible risk assessment procedures that can be revised soon in response to policy developments. Audit committees and compliance officers should work closely to stay current on the latest regulatory shifts, adjusting their oversight activities in real time rather than waiting for settled interpretations.

2. Maintain Vigilance Despite Perceived Relaxations

The temptation for corporate leadership to interpret recent DOJ actions, such as the temporary pause on FCPA enforcement, as a relaxation of compliance standards is substantial. However, compliance professionals must actively resist this complacency. The DOJ’s statutory enforcement authority remains unchanged; fraud statutes persist irrespective of administrative fluctuations. Maintaining vigilance ensures that your organization does not inadvertently plant seeds of unethical conduct that might grow unchecked into serious compliance breaches, potentially coming to light once regulatory priorities shift again.

3. Audit Committees Must Stay Proactive and Informed

The decision by DOJ officials not to appear at historically significant events such as the ABA’s annual White Collar Conference underscores a critical lesson. Compliance professionals and audit committees can no longer rely solely on traditional avenues of regulatory communication. It is imperative that they proactively seek out and engage with information through multiple channels, such as DOJ memoranda, policy announcements, speeches from senior leaders, and robust legal analyses provided by external compliance experts. Staying informed is not passive; it demands intentional and constant effort.

4. Preserve a Strong Compliance Culture

One significant risk associated with the current regulatory environment is the potential erosion of the culture of doing business ethically and in compliance within organizations. Perceptions of decreased regulatory scrutiny can lead to a relaxation of internal controls and risk assessment standards. To counter this, audit committees and compliance officers must consistently reinforce their commitment to compliance values, emphasizing to executive leadership and employees that compliance expectations remain unwavering, regardless of the current administration’s stated priorities. Compliance training and clear communication are essential in reinforcing the importance of ethical behavior, particularly during periods of perceived leniency.

5. Prepare for Expanded Compliance Responsibilities

The extensive issuance of Executive Orders by the Trump administration has created new and varied compliance obligations spanning healthcare, immigration, DEI initiatives, and federal contracting requirements. Audit committees and compliance professionals must closely monitor these developments and adjust their oversight practices accordingly. This requires expanding the scope of your compliance programs, creating additional controls and training tailored to these evolving obligations, and ensuring adequate staffing and resources.

6. Advocate for Adequate Compliance Resources

The turbulent regulatory landscape underscores the necessity for robustly funded and resourced compliance programs. Audit committees are critical in advocating for sufficient investment in compliance personnel, technology, and training. Now is not the time to diminish compliance budgets. It is an opportune moment to argue for greater investment, ensuring the compliance function is well-equipped to navigate ongoing volatility.

7. Educate, Train, and Communicate

Effective compliance education is paramount amid regulatory uncertainty. Ensure your workforce understands the current compliance requirements and the underlying rationale behind maintaining high compliance standards, even when immediate regulatory oversight may appear diminished. Addressing potential internal misperceptions head-on prevents employees from pushing ethical boundaries unnecessarily. Regular training sessions, town halls, compliance communications, and leadership messaging are vital to maintaining clear and consistent standards.

8. Uphold Accountability Through Caremark Standards

Despite administrative shifts, Delaware courts have shown no signs of loosening the stringent Caremark standards for director and officer oversight responsibilities. This underscores the critical importance of boards and audit committees in demonstrating robust compliance oversight. Compliance professionals must, therefore, continually remind board members of their fiduciary responsibilities and help them understand that maintaining rigorous compliance oversight is not just prudent—it’s legally essential.

Final Thoughts: The Compliance Imperative

The era ushered in by the second Trump administration has undeniably challenged compliance professionals and audit committees in unique ways, but it also presents an opportunity. By learning these lessons, embracing agility, maintaining vigilance, proactively seeking information, safeguarding compliance culture, expanding oversight responsibilities, advocating for resources, reinforcing education, and upholding accountability, compliance officers can effectively navigate regulatory turbulence and fortify their organizations against uncertainty.

The most successful compliance programs will view current challenges not as obstacles but as opportunities to deepen their organizational commitment to compliance, ethics, and integrity. As compliance professionals, our mission remains clear: to guide and protect our organizations through change, preserve trust, and ensure sustainability beyond any single administration’s tenure.

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Creativity and Compliance

Creativity and Compliance – Innovating Ethics: Creativity in Corporate Compliance with Katie Lawler

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 applies 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, Tom Fox and Ronnie Feldman are joined by Katie Lawler, EVP and Global Chief Ethics Officer at U.S. Bank.

They deeply dive into the importance of creativity in corporate ethics programs, particularly how innovative approaches help engage employees and drive behavior change. Katie shares insights on embedding ethics into daily operations, discussing successful initiatives like the ‘Ethics RideShare’ video series and ‘Ethics Mythbusters.’ They highlight balancing creativity with budget constraints, leveraging internal communication channels, and humanizing the ethics office to foster a more approachable environment. Tune in to discover actionable tips for making your compliance programs more engaging and effective.

Key highlights:

  • The Value of Creativity in Ethics Programs
  • Ethics Rideshare: A Creative Initiative
  • Humanizing Leadership During the Pandemic
  • Ethics Mythbusters: Debunking Common Misconceptions

Resources:

Katie Lawler on LinkedIn

 Ronnie

  • Compliance Confessions – inspired by “Mean Tweets,” these 90-second commercials address misconceptions and excuses to promote speak-up culture and the E&C team as positive and helpful.
  • E&C Training Jams – a soulful singer banters with ethics & compliance, explaining policies, sharing examples, and debunking excuses. 
  • Tales from the Hotline – Real speak-up-themed stories about workplace behavior gone wrong.
  • Workplace Tonight Show! – E&C meets SNL Weekend Update, explaining corporate risk topics and why employees should care.
  • 60-Second Communication & Awareness Shorts – A variety of short, customizable, music and multimedia, quick-hitter “commercials” promoting integrity, compliance, speaking up, and the E&C team as helpful advisors and coaches.
  • Custom Live & Digital Programing – Custom creative programming that balances the seriousness of the subject matter with a more engaging delivery. After all, you can’t bore people into learning.

 Tom

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Creativity and Compliance was recently honored as one of the Top 35 Podcasts on Creativity by Feedspot.

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Compliance Tip of the Day

Compliance Tip of the Day – Real-Time Compliance Scoring

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, we aim to provide 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.

Today, we look at how organizations are leveraging APIs to get real-time compliance scoring of their operations.