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Everything Compliance

Everything Compliance: The Flood Book, BOA, COIs and China ABC Edition

Welcome to a revamped Everything Compliance. New host Adam Turteltaub and new panelist Rebecca Walker join returning regulars Matt Kelly and Karen Moore for the next iteration of Everything Compliance. Jonathan is on assignment this week. Tom Fox joins the EC Gang as a special guest panelist. Fan favs Shout Outs and Rants end this week’s episode.

  • Karen Moore reviews China’s draft cross-border anti-corruption law, including mandatory compliance programs and reporting of suspected misconduct. She comments on the complexity of everyday life.
  • Tom Fox discusses risk-management lessons from his latest book, Deluge Before Dawn. He shouts out to AI bots hanging out at dinner parties and Happy Hours.
  • Rebecca Walker reviews COIs when senior execs or Board members oversee investigations of their colleagues. She shouts out about the recently released DOJ National Fraud Enforcement Division Directive and the information it provides compliance professionals.
  • Matt Kelly looks at Bank of America’s $1.2B AML settlement. He rants about Tesla’s new flying car and shouts out to BJ Wholesale Club.
  • Adam Turteltaub is our fearless leader. He shouts out to compliance professionals at non-financial institutions reviewing their AML programs and to the Milwaukee Brewers for beating his Dodgers to win their first World Series in 44 years.

The members of Everything Compliance are:

The award-winning Everything Compliance is a part of the Compliance Podcast Network.

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Innovation in Compliance

Innovation in Compliance: Jeff Kushner on GRC Lessons from Kerrville 2025: Why a Policy Isn’t a Control

Innovation comes in many areas, and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance, as he speaks with top innovators, thinkers, and creators on the award-winning Innovation in Compliance podcast. In this episode, host Tom interviews GRC professional Jeff Kushner about Fox’s book Deluge Before Dawn and its risk management lessons from the 2025 Kerr County flood that killed 119 people.

Kushner argues a policy is not a control: policies must be specific, operationalized, tested, monitored, and continuously improved, with clear roles, successor plans, training, and communication protocols. He contrasts document-centric assurance (having a written plan and passing inspections) with outcome-centric assurance (whether plans work in real conditions), citing Camp Mystic’s one-page “shelter in place” plan that passed a DSHS inspection two days before the flood. They discuss alerts as information that requires predetermined response sequences, the need for redundancies in communications, proactive scenario exercises (“what happens next?”), benchmarking against other sites like Mo Ranch, and board-level questions on impact, accountability, timelines, and measurable protections for life, property, and data. Kushner also describes his role at Allgress and its Rexina solution for identifying compliance and risk changes and guiding remediation.

 

Key Highlights:

  • Policy Versus Control
  • Alerts and Control Steps
  • Inspection Paradox
  • Outcome-Based Assurance
  • Scenario Testing Exercises
  • Rexina and Allgress
  • Board-Level Risk Questions

Resources:

Jeff Kushner on LinkedIn

Allgress

Allgress on LinkedIn

Allgress/Rixena

For a report Jeff Kushner created on the risk management issues we discussed in the podcast, click here.

Tom Fox

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Sunday Book Review

Sunday Book Review: September 13, 2026, The New Books Leadership Edition

In the Sunday Book Review, I consider books that would interest the compliance professional, the business executive or anyone who might be curious. It could be books about business, compliance, history, leadership, current events or anything else that might interest me. In this episode, we look at 4 new books on leadership that have or will be released in the fall 2026.

  1. How Leaders Can Inspire Accountability by Michael Timms
  2. Begin with We by Kyle McDowell
  3. Leadership Intelligence by Caroline Webb
  4. Superteams by Ronald Friedman

 

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County Texas which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival and resilience. It is available on the following sites:

 Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

 

This week only, the e-book Kindle version is available for $0.99 on Amazon