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Compliance Tip of the Day

Compliance Tip of the Day – How Compliance Can Leverage Agentic AI Systems

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 continue our exploration of Agentic AI by considering how compliance can leverage Agentic AI systems.

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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Daily Compliance News

Daily Compliance News: February 4, 2025, The Reframing not Retreating Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Consumer Financial Protection Bureau Ordered To Stop Work. (Forbes)
  • DEI-reframing, not retreating. (FT)
  • Trafigura and ex-COO were convicted of bribery. (Bloomberg)
  • How Binance is ensuring compliance. (CoinPedia)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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Blog

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

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

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

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

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

Leadership Intervention: Setting the Tone from the Top

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

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

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

Concept in Action: Rewarding Compliance Innovation at DBS Bank

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

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

Data Empowerment: Making Compliance Everyone’s Job

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

This means focusing on three levels of readiness:

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

Concept in Action: JPMorgan Chase and the DeepRacer Challenge

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

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

Collaboration: Breaking Down Compliance Silos

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

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

To fix this, compliance functions must invest in:

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

Concept in Action: Gulf Bank’s Data Ambassador Program

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

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

Value Realization: Measuring and Celebrating Compliance Success

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

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

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

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

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

The results?

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

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

Compliance in the Age of AI

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

The key takeaways?

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

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

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FCPA Compliance Report

FCPA Compliance Report – DeepSeek and the Recalibration of Risk with Mike Huneke and Brent Carlson

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Mike Huneke and Brent Carlson for a special two-part podcast series on DeepSeek’s bombshell AI advancements announced on President Trump’s inauguration day. In Part 1, they review the business and compliance implications, and in Part 2, they consider the Sputnik Moment that has occurred.

In Part 1, they consider the immediate and significant repercussions in both the business and compliance landscapes. Key topics include the economic and geopolitical ramifications of DeepSeek’s innovations, changes in export control policies, and the unique compliance challenges AI technology poses. The discussion also examines how corporations can recalibrate their risk frameworks, integrate high-probability standards, and leverage data analytics to handle millions of transactions in a global economy. Emphasizing the importance of comprehensive compliance programs, the episode provides actionable insights for compliance professionals navigating this evolving landscape.

Key highlights:

  • DeepSeek’s AI Breakthrough
  • Economic and Compliance Implications
  • Export Controls and Legal Concerns
  • Compliance Strategies and Risk Management
  • Training and Organizational Culture

Resources

Mike Huneke

Hughes Hubbard & Reed website

Brent Carlson on LinkedIn

A Fresh Look at US Export Controls and Sanctions

DeepSeek Finds US Export Controls at a New ‘Sputnik Moment’ in Bloomberg.Law

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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Compliance Tip of the Day

Compliance Tip of the Day – Introduction to Agentic AI for Compliance

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 begin a look at Agentic AI and how it can be used in compliance.

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 31 – Leveraging Root Cause Analysis for Effective Compliance

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this final episode of our 31-day series, we dive into the importance of using root cause analysis for remediation in compliance programs. Emphasized by the ECCP and DOJ, an effective compliance program includes thorough root cause analysis to address misconduct and implement corrective actions. The process involves understanding who should perform the remediation, emphasizing independence and objectivity, integrating the information into solutions, and addressing deficiencies in internal controls. Key takeaways include using objective root cause analysis, effectively utilizing the information gathered, and implementing data-driven, repeatable solutions to prevent future issues. This episode provides valuable insights for compliance officers aiming to enhance their programs by focusing on root causes rather than just symptoms.

Key highlights:

  • Integrating Root Cause Analysis into Solutions
  • Regulatory Expectations and Internal Controls
  • Performing Effective Root Cause Analysis
  • Developing and Implementing Solutions

Resources:

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

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FCPA Compliance Report

FCPA Compliance Report – Jag Lamba on Navigating Compliance Challenges in a Rapidly Changing World

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Jag Lamba, CEO of Certa.AI, the podcast’s sponsor.

We look at the recent events involving economic and trade sanctions levied on Colombia (now withdrawn) and the announcement of DeepSeek as a cost-effective competitor to ChatGPT in the AI space to discuss how quickly your risks can change. We overlay this discussion through the lens of the DOJ’s 2024 Update on the Evaluation of Corporate Compliance Programs (2024 ECCP). Jag provides insights on how compliance officers can proactively manage risk amidst rapidly changing global landscapes by ensuring their programs are well-designed, adequately resourced, and effective. Key takeaways include the importance of data, controls, and technology in building robust compliance frameworks and using business impact and ROI to secure necessary resources.

Key highlights:

  • Current Events Impacting Compliance
  • 2024 ECCP-Designing a Well-Structured Compliance Program
  • 2024 ECCP-Adequate Resourcing for Compliance Programs
  • 2024 ECCP: Effectiveness of Compliance Programs in Practice
  • Proactive Risk Management Strategies
  • Export Controls and Compliance Challenges

Resources:

Jag Lamba on LinkedIn

Certa.ai

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Daily Compliance News

Daily Compliance News: January 31, 2025, The Done with Corruption Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Menendez was sentenced to 11 years in prison. (FoxNews)
  • Serbians are done with corruption. (The Guardian)
  • Process-Centric Compliance. (Forbes)
  • Stanford fraud case ends. (Reuters)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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Blog

Compliance and Agentic AI – Building Trust, Part 3

The rise of agentic artificial intelligence (AI) is one of the most transformative developments in recent memory, particularly for legal and compliance professionals. No longer limited to passive interactions or answering questions, AI has evolved into a tool capable of reasoning, making decisions within pre-defined parameters, and taking actions autonomously. As businesses explore the potential of these technologies, compliance professionals find themselves at the forefront of ensuring that this innovation occurs within the guardrails of trust, privacy, and ethical accountability.

In a recent article in Bloomberg entitled Using AI Agents Requires a Balance of Trust, Privacy, Compliance author Sabastian Niles, President and Chief Legal Officer of Salesforce, discussed the role of AI agents today and in the future. Understanding this new breed of AI is essential for compliance professionals to harness its power responsibly while safeguarding trust, privacy, and compliance. Over this three-part blog series, I have explored what Agentic AI systems are and how the compliance profession can use them. Today, we conclude by looking at key issues compliance will face, including trust, privacy, and ethical accountability.

Trust is the bedrock upon which all successful technology implementations are built, and when it comes to agentic AI, trust is not just a nice-to-have; it is non-negotiable. For compliance professionals, fostering trust in AI systems is a dual challenge: balancing the excitement of innovation with the ethical and regulatory responsibilities that come with it. Without trust, even the most sophisticated AI systems can fail to deliver their promised value, exposing organizations to legal, reputational, and operational risks.

The cornerstone of this trust lies in three critical areas: data integrity, transparency and explainability, and regulatory alignment.

Data Integrity: Building AI on a Solid Foundation

AI agents are only as reliable as the data they process. The outputs will follow suit if the inputs are flawed—whether through bias, inaccuracy, or incompleteness. Compliance professionals must ensure the organization’s data ecosystem is robust, curated, and reflects organizational values. Steps a compliance professional can take to strengthen data integrity include the following:.

  1. Centralize Data Management. Fragmented data sources increase the risk of inconsistencies. Establish unified systems that pool data into a single source of truth, ensuring consistency across all AI-driven processes.
  2. Validate Inputs and Outputs. Build systems that validate data inputs for accuracy and continuously monitor AI outputs. This safeguards against deviations or unintended consequences as the AI evolves.
  3. Eliminate Bias. Conduct bias audits on datasets to ensure fair and equitable outcomes. For example, compliance teams using AI to monitor transactions for fraud must ensure that the data does not unfairly target specific regions or demographics.

When compliance professionals champion high-quality, unbiased, and unified data, they provide a strong foundation for building trust in AI systems.

Transparency and Explainability: Demystifying the Black Box

One of the most common concerns about AI, particularly agentic AI, is its Black Box quality. How did the system arrive at a specific decision? Was it a fair decision? Could it have been influenced by flawed data or programming? Transparency and explainability are key to addressing these questions. For compliance professionals, the goal is to ensure that AI decisions are understandable and defensible. Regulators, employees, and customers will demand to know how AI systems operate, especially when decisions impact them directly. A compliance function can prioritize transparency using the following strategies:.

  1. Document Decision-Making Processes. AI systems must be designed to log their decision-making rationale. This documentation can be a critical audit trail during internal reviews or regulatory inquiries.
  2. Promote Explainable AI. Collaborate with IT and AI teams to prioritize explainability, even if it means sacrificing some degree of complexity. The ability to explain why an AI flagged a transaction or how it recommended a course of action builds confidence among stakeholders.
  3. Train Stakeholders. Ensure that key stakeholders understand the basics of how the AI system operates, its limitations, and when human oversight is required.

Transparency and explainability are not just technical features; they are trust-building tools. Compliance professionals who advocate for these principles will strengthen stakeholder confidence in AI systems.

Regulatory Alignment: Staying Ahead of the Curve

As Agentic AI continues to evolve, so will the regulatory landscape. Policymakers worldwide are introducing AI-specific regulations, such as the EU Artificial Intelligence Act or Colorado’s state-level Consumer Protections for Artificial Intelligence. These frameworks ensure that AI systems operate ethically, securely, and transparently. For compliance professionals, this represents both a challenge and an opportunity. 

  1. Embed Privacy-by-Design Principles. Incorporate data privacy protections at every stage of AI development, ensuring compliance with laws like GDPR, CCPA, and beyond.
  2. Monitor Emerging Regulations. Monitor evolving AI regulations and assess how they impact your organization. Assign dedicated resources to regulatory monitoring to stay ahead of changes.
  3. Collaborate Across Functions. Work with legal, IT, and data governance teams to ensure AI systems meet or exceed regulatory standards from day one.

Compliance professionals have a unique role in translating complex regulatory requirements into actionable strategies. By embedding regulatory alignment into AI systems, they help their organizations avoid legal pitfalls and foster long-term trust.

Building Ethical Guardrails: The Compass for Responsible AI 

Trust in AI is not just about compliance; it is also about ethics. The responsible adoption of agentic AI hinges on establishing ethical guardrails that ensure innovation does not come at the expense of integrity. These guardrails serve as both a compass and a safety net, guiding the organization as it navigates the complexities of AI deployment. You should employ several key ethical guardrails.

  1. Transparency in Decision-Making. AI systems must document and communicate their decision-making processes. This ensures that humans can intervene when needed.
  2. Risk Mitigation. Conduct comprehensive risk assessments for all AI use cases, identifying vulnerabilities and implementing safeguards to address them.
  3. Human Escalation Pathways. Define clear parameters for when and how human oversight is required. Even the most advanced AI systems should not operate entirely without human involvement.
  4. Privacy Protections. Privacy-by-design principles should be central to every AI deployment, ensuring compliance with data protection laws and safeguarding customer trust.

By championing ethical AI practices, compliance professionals can help their organizations harness the power of agentic AI while mitigating its risks.

Balancing Innovation with Compliance: A Strategic Opportunity

The perception of compliance as a business blocker is outdated. Agentic AI allows compliance teams to position themselves as enablers of innovation. Compliance professionals can enhance business outcomes and stakeholder trust by guiding organizations to adopt AI responsibly and strategically. There are multiple steps that a corporate compliance function can take and inculcate in your organization.

  1. Educate Your Team. Develop a plan to increase your team’s understanding of agentic AI—Foster cross-functional collaboration between compliance, IT, and business units to ensure alignment.
  2. Shift the Mindset. Move beyond the “Is this legal?” to ask, “How can we do this responsibly?” This positions compliance as a driver of ethical innovation.
  3. Audit Your Data Ecosystem. Conduct a thorough review of your organization’s data sources, addressing inaccuracies and ensuring readiness for AI processing.
  4. Update Policies. Revise acceptable use policies to address the unique risks of agentic AI, ensuring alignment with organizational values and emerging regulations.
  5. Prioritize Trust. Without definitive laws, meeting or exceeding customer privacy and security expectations can be a competitive advantage.

The Path Forward: Trust as a Strategic Asset

Adopting Agentic AI systems marks a transformative moment for compliance professionals and the corporate compliance function. By embedding trust into every aspect of AI deployment through data integrity, transparency, regulatory alignment, and ethical guardrails, compliance teams can help their organizations navigate this new era and thrive in it. By championing trust, compliance professionals can become strategic partners in their organizations’ AI journeys, proving that ethics and innovation are not opposing forces; they are complementary pillars of success. As always, compliance begins with trust. In the Agentic AI era, trust is not just foundational but transformational.

The rise of AI is not just a technological shift; it’s a cultural and ethical one. It’s an opportunity for compliance professionals to redefine their roles, demonstrating that trust and innovation coexist. In this new frontier, the organizations that strike the right balance between trust, privacy, and compliance will succeed and set the standard for the entire industry.  As Niles aptly puts it, this is not just about adopting new tools but transforming organizations’ operations. And in that transformation lies the promise of a more efficient, resilient, and ethical future.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 30 – The Foreign Extortion Prevention Act

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 30, we discuss the Foreign Extortion Prevention Act (FEPA), a significant piece of legislation that fills a critical gap in the FCPA. FEPA criminalizes not only the payment of bribes but also the solicitation and acceptance of bribes by foreign officials, thereby providing a more comprehensive framework for combating global corruption. This law protects American workers abroad, promotes fair business competition, and upholds ethical practices internationally. However, it also introduces challenges, such as the complexity of extraditing foreign officials and potential impacts on international relations and companies operating overseas. Compliance officers must reassess internal controls and develop response plans to navigate the implications of FEPA effectively.

Key highlights:

  • Filling the Gap in Anti-Corruption Laws
  • Key Features and Implications of FEPA
  • Challenges in Implementing FEPA
  • The Name and Shame List

Resources:

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