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10 For 10

10 For 10: Top Compliance Stories For the Week Ending February 22, 2025

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • You can take the KFC out of Kentucky. (NYT)
  • Grand jury investigating Synapse fraud.(WSJ)
  • Patel and Shein. (WSJ)
  • CTA back on. (WSJ)
  • DOJ guts bringing of corruption cases.(CNN)
  • Barclay’s faces money-laundering investigation. (WSJ)
  • Is settling litigation paying a bribe? (WSJ)
  • Wells Fargo Consent Decree terminated. (YaHooFinance)
  • JPMorgan purchase of Frank heads to criminal trial. (FT)
  • Of business plans and tariff changes. (Bloomberg)

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

You can check out the Daily Compliance News for four curated compliance and ethics related stories each day, here.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 46 – The Move to Diligent 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:

  • JPMorgan’s purchase of Frank heads to criminal trial. (FT)
  • Dirty money, fentanyl, Mexican gangs, and China. (WSJ)
  • Mayor Adams imbroglio (Various)
  • McKinsey asks if China is too risky. (Bloomberg)
  • Ethics programs are more than simply compliance. (Forbes)
  • Wells Fargo banks on (Not) risky business. (PYMTNS)
  • Diligent Acquires Spark Compliance, a Leading Compliance and Ethics Consultancy (Press Release) – HERE
  • Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security (Whitehouse) – HERE
  • The Corporate Transparency Act Is Back On (WSJ) – HERE
  • Study Warns on Ethical Culture Disconnect (Radical Compliance) –HERE
  • Florida woman, 44, uses ‘botox’ excuse to explain age after fraudulently applying for hurricane aid: police (Fox News): HERE

 

Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

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Compliance Into the Weeds

Compliance into the Weeds: The DOJ in Crisis

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recent astonishing developments at the Justice Department involving the indictment and subsequent attempted dismissal of charges against New York City Mayor Eric Adams.

Tom and Matt explore the implications for corporate compliance professionals and the broader message this dysfunction sends about ethics and the role of compliance programs under the current administration. They consider the possible repercussions for future corporate enforcement, drawing important parallels between the Justice Department’s actions and the expectations for corporate compliance. They emphasize the necessity of disentailing the ethical dysfunction at the department from the practical guidelines for compliance programs. The episode critically analyzes how political maneuvers affect the justice system and corporate compliance standards.

Key highlights:

  • The Eric Adams Indictment
  • Resignations and Internal Conflict
  • Separating DOJ Integrity from Compliance Guidance
  • Tone at the Top vs. Mood at the Middle
  • Future of Compliance Guidelines

Resources:

Matt in Radical Compliance

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Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

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Daily Compliance News

Daily Compliance News: February 17, 2025, The Cancel The Leases 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:

  • Retaliation? Musk and DOGE want to cancel federal judiciary leases. (Reuters)
  • DOJ guts bringing of corruption cases. (CNN)
  • Barclay faces a money-laundering investigation. (WSJ)
  • Is settling litigation paying a bribe? (WSJ)

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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FCPA Compliance Report

FCPA Compliance Report – National Security and Legal Perspectives with Kevin Carroll

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Kevin Carroll, now a partner at Fluet, to discuss national security issues to date under the Trump Administration.

Kevin Carroll discusses his move to Fluet Law, a national security law firm. He delves into the ongoing chaos in national security, ranging from employees’ concerns over legal processes at the Agency for International Development and the FBI to the unprecedented moves of the Trump administration in reprioritizing enforcement efforts. Kevin emphasizes the criticality of maintaining international alliances and intelligence-sharing, especially amidst controversial DOJ staffing and enforcement decisions. They also touch on the potential ramifications for U.S. companies engaged in foreign trade and anti-corruption enforcement. Don’t miss Kevin’s expert insights on the delicate balance of national security and legal frameworks in uncertain times.

Key highlights:

  • Kevin’s New Professional Chapter
  • National Security Concerns
  • Law Enforcement Priorities
  • International Relations and Security
  • Corporate Legal Risks Abroad
  • USAID and Export Control

Resources:

Kevin Carroll on LinkedIn

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

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Everything Compliance

Everything Compliance: Episode 150, The Musk On Edition

Welcome to this edition of the award-winning Everything Compliance. In this episode, Matt Kelly, Jonathan Armstrong, Jonathan Marks, Karen Woody, and Karen Moore join the full gang to examine various issues for compliance professionals under the incoming administration.

  1. Jonathan Armstrong looks at the car crash coming for DeepSeek in the EU. He shouts out to Peter Mandelson, the new UK Ambassador to the United States.
  2. Karen Moore looks at the reframing of DEI. She shouts out about the film on September 5.
  3. Matt Kelly considers the Bondi Memo on changes in DOJ enforcement focus and mentions Alexei Navalny’s memoir.
  4. Karen Woody examines the new SEC Crypto Taskforce and mentions the award-winning play Hadestown.
  5. Jonathan Marks provides a tutorial on the role of internal audit on export controls. He also shouts out to his hometown team, the Philadelphia Eagles (now the Super Bowl-winning Philadelphia Eagles).
  6. Tom Fox shouts out to (conspiracy) Bill Simmons for opining that the Dallas Maverick’s trade of Luka Doncic was a ploy to force the state of Texas to allow gambling in this state.

The members of Everything Compliance are:

The host and producer, rantor (and sometime panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the award-winning Compliance Podcast Network.

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

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending February 8, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings you the compliance professional and the compliance stories you need to know to end your busy week. Sit back, and in 10 minutes, hear the stories every compliance professional should know from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • Fay Vincent warned MLB of the corruption from gambling. (NYT)
  • Do we need eyes on compliance gatekeepers? (The Regulatory Review)
  • MLB fires ump for shared betting accounts. (ESPN)
  • WVU replaces DEI with “Dept. of Engagement and Compliance”. (12WBOY)
  • Will Trump DOJ drop corruption charges against NYC Mayor? (Reuters)
  • Shien IPO runs into Uyghur issues. (Reuters)
  • Top SEC crypto lawyer reassigned to IT. (WSJ)
  • Pam Bondi confirmed as new AG. (Bloomberg)
  • Bondi cuts back on FCPA enforcement. (Radical Compliance)
  • Is the Rooney Rule still legal? (Bloomberg)

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

You can check out the Daily Compliance News, which features four curated compliance and ethics stories each day here.

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Daily Compliance News

Daily Compliance News: February 3, 2025, The Division of Engagement and Compliance 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:

  • Congress says Nvidia chip flow to China should be stopped. (WSJ)
  • The CCO Departure Bonus. (Cosmos)
  • WVU replaces DEI with “Dept. of Engagement and Compliance”. (12WBOY)
  • Will Trump DOJ drop corruption charges against NYC Mayor? (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

From Sanctions to AI Disruption: How Compliance Officers Can Navigate the Rapid Pace of Change

The pace of change in today’s global business environment is breathtaking. Events that unfold over a weekend can have massive implications for corporate compliance professionals by Monday morning. When there is a business change, risks constantly change. Over the past week, this was demonstrated with two seemingly unrelated but equally impactful developments:

  • The U.S. is imposing sanctions on Colombia because of its alleged failure to take back migrants, including a 25% tariff on goods imported from the country.
  • The emergence of DeepSeek, a Chinese AI company that has developed a large language model rivaling OpenAI’s ChatGPT—at a fraction of the cost.

For the compliance professional, what do these risks mean for your organization? What do you think about a framework for assessing and managing these risks as they raise critical compliance concerns spanning sanctions enforcement, export controls, supply chain transparency, and regulatory readiness? In the most recent episode of the FCPA Compliance Report, I explored these issues with Jag Lamba, CEO at Certa.ai. We focused on the Department of Justice (DOJ) framework in its 2024 Update to the Evaluation of Corporate Compliance Programs (2024 Update) to make sense of and respond to these rapid developments.

The DOJ’s framework in the 2024 Update is broken down into three key components:

  1. Is the compliance program well-designed?
  2. Is the compliance program adequately resourced and empowered to function effectively?
  3. Does the compliance program work in practice?

We applied these elements to the recent developments and explored how compliance professionals can prepare for similar shocks in the future.

  • Is Your Compliance Program Well-Designed to Handle Rapidly Emerging Risks?

The first test of a compliance program is whether it is designed to assess, identify, and mitigate risks promptly. The DOJ has emphasized real-time risk assessment—a shift from static, once-a-year reviews to continuous monitoring.

Take the U.S. sanctions against Colombia. This was not a predictable, drawn-out regulatory action. It happened over a weekend, and by Monday, businesses importing Colombian goods faced a 25% tariff with little time to prepare. Compliance officers had to:

  1. Quickly identify how much of their supply chain relied on Colombian imports.
  2. Determine if alternatives existed to mitigate the cost impact.
  3. Communicate rapidly with leadership to ensure the company could pivot operations where needed.

A traditional, slow-moving risk assessment process would have left companies flat-footed. Instead, an agile risk management system, leveraging real-time data analytics and automated monitoring, can help companies proactively spot emerging risks before they become crises.

The same logic applies to export controls in the tech sector, especially in light of the DeepSeek development. Compliance officers at major AI and semiconductor companies must now be asking:

  1. Who are our customers in Singapore and neighboring markets?
  2. Are our chips being resold or rerouted to sanctioned entities in China?
  3. Do we have automated tools to track and verify shipments to ensure compliance with U.S. export control laws?

It may be too late to prevent regulatory scrutiny if a company relies on manual risk assessments and outdated compliance processes.

  • Is Your Compliance Program Adequately Resourced and Empowered?

The DOJ has clarified that a compliance program is only as good as the resources allocated to it. Ten years ago, the conversation centered around whether compliance officers had direct access to the board. The conversation then shifted to the quality of your Chief Compliance Officer (CCO) and compliance personnel. Today, the discussion is shifting to whether compliance has the technology, data, and personnel necessary to operate effectively.

Consider the situation with NVIDIA and its skyrocketing sales in Singapore—a market that, while business-friendly, is geographically close to countries facing strict U.S. export controls. Regulators are undoubtedly scrutinizing this data. The question for NVIDIA’s compliance team is:

  1. Do they have the visibility to track where these chips are ending up?
  2. Are they able to monitor sales intermediaries in real time?
  3. Can they preemptively flag anomalies—such as a single country purchasing a huge volume of restricted technology?

Without AI-driven compliance monitoring and data analytics, even the best compliance teams risk being overwhelmed by the sheer volume of transactions and regulatory changes.

Similarly, companies impacted by the Colombian tariffs must ensure their compliance programs have the right supply chain monitoring tools to:

  1. Identify impacted suppliers instantly.
  2. Assess alternative sourcing options without regulatory hurdles.
  3. Develop contingency plans to mitigate financial and operational risks.

This compliance function cannot be effectively run using spreadsheets and email chains. Companies must invest in data automation, AI-driven analytics, and cross-functional collaboration tools to avoid such fast-moving regulatory changes.

  • Does Your Compliance Program Work in Practice?

Finally, compliance programs must not exist solely on paper but must demonstrate real-world effectiveness. The DOJ’s 2024 Update mandates data-driven evidence to assess whether a compliance program is functional and effective.

This means compliance teams must be able to show:

  1. How many third-party vendors and intermediaries have been vetted and monitored?
  2. How export controls are enforced in practice—not just documented in policy.
  3. How quickly can the company respond to a sudden regulatory change, such as the Colombian sanctions?

One of the best ways to demonstrate effectiveness is through compliance storytelling. A compliance officer should be able to present:

  • This is a clear narrative backed by data showing how the company detected and addressed a regulatory risk before it became a crisis.
  • These are case studies of how compliance actions have improved business outcomes—for example, reducing onboarding time for sales intermediaries without compromising compliance integrity.
  • Tangible evidence includes video training logs, compliance dashboards, and documented decision-making trails.

A powerful example comes from a Fortune 100 company that secured five years of compliance funding in one go rather than having to renegotiate budgets annually. How? By presenting compliance in business terms:

  • Demonstrating how compliance efficiencies improved sales and reduced onboarding delays.
  • Showing the financial impact of proactive risk management.
  • Using data-driven evidence to justify long-term compliance investments.

This is the future of compliance: a function that prevents regulatory risk and actively contributes to business strategy and growth.

The CCO as a Strategic Risk Navigator

The recent developments with Colombian sanctions and DeepSeek’s AI breakthrough highlight how fast compliance risks can evolve. Sanctions, export controls, and regulatory enforcement actions are no longer slow-moving threats—they can materialize overnight.

The DOJ’s 2024 Update provides a clear roadmap for compliance professionals to navigate these challenges:

  1. Risk assessment must be dynamic and continuous. Compliance programs must be designed to identify risks in real-time, not just during annual reviews.
  2. Compliance must be adequately resourced. Companies must invest in technology, data analytics, and automation to meet regulatory changes.
  3. Compliance must demonstrate real-world effectiveness. Data-driven evidence, compelling narratives, and tangible business impact must back compliance programs.

Compliance professionals who embrace data-driven decision-making, automation, and proactive risk management will not only survive but thrive in this era of regulatory volatility. The question is: Is your compliance program ready for the next unexpected headline?

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Daily Compliance News

Daily Compliance News: January 29, 2025, The End to Black History Month 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:

  • State Department prohibited from celebrating Black History Month. (WSJ)
  • Is DeepSeek real? (FT)
  • DOJ Public Corruption Unit Chief resigns. (Bloomberg)
  • Using AI agents requires trust and compliance. (Bloomberg)

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.