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Everything Compliance

Everything Compliance: Episode 162, The Numbers, Numbers, Numbers Edition

Welcome to this Edition of award-winning Everything Compliance. In this episode, we have the quartet of Matt Kelly, Jonathan Marks, and special guests Lisa Fine and Dr. Hemma Lomax with Tom Fox, the Compliance Evangelist, as host.

1. Matt Kelly looks at the recent Millicom Cellular FCPA enforcement action.  He shouts out to the ChatGPT em-dash and rants about the federal government’s attempts to ban all state regulation of AI.  

2. Jonathan Marks reviews the failures of internal controls in the NBA and MLB around the ongoing betting scandals. He shouts out MacKenzie Scott for her $70 million donation to Historically Black Colleges and Universities (HBCUs) in 2025, continuing her support after a $560 million donation to 27 HBCUs in 2020. 

3. Special Guest Panelist Dr. Hemma Lomax considers where Agentic AI in compliance is heading. She rants about ChatGPT em dashes and shouts out recent legal tech conferences.  

4. Special Guest Panelist Lisa Fine looks at three key issues on her mind about compliance for 2026. She shouts out to the Compliance Week survey, Inside the Mind of the CCO, and encourages all listeners to participate.  

5. Tom Fox shouts out to Gen Z and their play with the numbers 6 and 7 and traces the use of numerology in texts back to the Book of Genesis and the ancient text of Gilgamesh.  

The members of Everything Compliance are:

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

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Great Women in Compliance

Great Women in Compliance – GWIC Joins Everything Compliance

Today, we have a special joint episode of GWIC and Everything Compliance. Lisa Fine and Hemma Lomax recently joined Matt Kelly and Jonathan Marks for an episode of Everything Compliance (Episode 162—the Numbers Numbers Numbers edition), which will post on Thursday, December 4. We are cross-posting the episode here on Great Women in Compliance.

Lisa Fine, Hemma Lomax, Matt Kelly, and Jonathan Marks each bring a unique perspective to the discussion of corporate corruption and the intersection with drug cartels, as exemplified by the Millicom Cellular case. Lisa highlights the need to understand the risks associated with smaller markets and the complexities of joint ventures, advocating for enhanced compliance education and vigilance to mitigate cartel-related corruption. Hemma underscores the importance of integrating proactive compliance measures and automation, promoting “everyday integrity as a service” to preempt issues like bribery and data leakage. Meanwhile, Matt and Jonathan focus on the structural vulnerabilities in governance and the critical need for transparency and robust monitoring systems to prevent the entanglement of corporate operations with cartel activities, cautioning against underestimating the risks in seemingly low-revenue markets.

 Highlights include:

  • Millicom Cellular: Corporate Corruption and Cartel Connections
  • Enhancing Compliance through Systematic Involvement Strategies”
  • AI-Driven Real-Time Risk Detection in Compliance
  • Enhancing Governance to Prevent Sports Betting Scandals
  • Regulatory Changes in the Global Compliance Environment
  • AI-Enhanced Policy Clarity and Management Techniques
  • Raves and Rants
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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 64 – The Hardest Year 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:

  • FCPA Enforcement Is Happening! – Radical Compliance – HERE
  • Where in the Loop? Testing AI Across 120 Compliance Tasks to Find Out Where Humans Are Most Needed – CCI – HERE
  • Charlie Javice Billed Hotels and Cellulite Butter as Legal Fees, JPMorgan Says – Wall Street Journal – HERE
  • General Counsel on Demand: Why High-Risk Sectors Are Embracing the Fractional Model – CCI – HERE
  • The $1tn Man tells workers 2026 will be the ‘hardest year.’ (BusinessInsider)
  • Top Ukrainian energy ministers resign. (AP)
  • Hundreds of thousands protest in the Philippines against corruption. (NPR) And protests rage in Mexico over corruption. (NYT)
  • They really don’t want to pay her attorney’s fees.  (WSJ)
  • The Lakers are being investigated in an NBA betting scandal.  (ESPN)
  • Florida man wearing ‘No, seriously, I have drugs’ T-shirt arrested for drug possession—The Week – HERE.

Connect with the Hosts:

Resources:

Kristy Grant-Hart on LinkedIn

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Tom

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending, November 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 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 Tom Fox, the Voice of Compliance. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

Top stories this week include:

  • Indonesia is looking into Chinese corruption over the high-speed train. (SCMP)
  • The tariff argument goes poorly for the Administration at the Supreme Court. (Reuters)
  • Norwegian Sovereign Wealth Fund votes against Musk’s $1tn pay package. (WSJ)
  • NBA Reports to Congress on Gambling Probe. (The Athletic)
  • Capula’s former CCO claims retaliation for whistleblowing as the reason for termination. (Bloomberg)
  • BaFin slaps €45MM fine on JPMorgan. (FT)
  • Trump threw a temper tantrum over corruption Q. (The Daily Beast)
  • SBF says trial ‘fundamentally unfair’. (FT)
  • State capture and corruption. (The Guardian)
  • Sex dolls, compliance, and Shein. (WSJ)

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

Connect with Tom 

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You can purchase a copy of my new book, Upping Your Game, on Amazon.com

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Daily Compliance News

Daily Compliance News: November 7, 2025, The Do $1tn Pay Packages Really Incentives You 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, including compliance, ethics, risk management, leadership, or general interest, relevant to the compliance professional.

Top stories include:

  • NBA Reports to Congress on Gambling Probe. (The Athletic)
  • Capula ex-CCO claims retaliation for whistleblowing in termination. (Bloomberg)
  • BaFin slaps a €45 million fine on JPMorgan. (FT)
  • Will Elon Musk really work harder for a $1 trillion pay package? (NYT)

The Daily Compliance News has been honored as No. 2 in the Best Regulatory Compliance Podcasts category.

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Compliance Tip of the Day

Compliance Tip of the Day – NBA Betting Scandal – Rebuilding a Culture of Integrity

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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 will mine the ongoing NBA betting scandal for compliance lessons. Today, in this concluding Part 5, we conclude by looking at what the NBA itself can do to rebuild trust with its stakeholders.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 63 – The Farewell to the Tall Guy 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:

  • Boeing hit with $5bn in late fee penalties. (BBC)
  • All about FATF. (Bloomberg)
  • Will Tesla lose Musk (w/o $1tn pay package)? (Yahoo!Finance)
  • Does insider trading = insider betting? (Bloomberg)
  • Tom Hayes sues UBS for $400M. (Reuters)
  • SEC Chair Talks Messaging Enforcement, Misses the Point – Radical Compliance
  • Corruption Probe Underway at Rio Tinto’s Mongolian Copper Mine – WSJ
  • Facebook’s new holiday ad pines for a social platform that’s long gone – Fast Company
  • CEOs Are Furious About Employees Texting in Meetings – WSJ
  • Florida man arrested after making bomb threat against himself: police – WFLA

Connect with the hosts:

Resources:

Kristy Grant-Hart on LinkedIn

Prove Your Worth

Tom

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Compliance Tip of the Day

Compliance Tip of the Day – NBA Betting Scandal – A Short History of BasketBall Betting Scandals

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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 will mine the ongoing NBA betting scandal for compliance lessons. Today in Part 3, we look at the history of sports betting scandals in basketball over the past 60 years.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Compliance Tip of the Day

Compliance Tip of the Day – NBA Betting Scandal – Prop Bets and Sports Books

Welcome to “Compliance Tip of the Day,” the podcast that brings 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 goal is to provide you with bite-sized, actionable tips to help you stay ahead in your compliance efforts. 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 will mine the ongoing NBA betting scandal for compliance lessons. Today in Part 2, we look at the role of prop bets and sports books in the scandal.

For more information on this topic, refer to The Compliance Handbook: A Guide to Operationalizing Your Compliance Program, 6th edition, recently released by LexisNexis. It is available here.

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Blog

The NBA Betting Scandal, Part 5: Rebuilding Trust – The NBA’s Path Toward Integrity

In the span of a single week, the NBA went from celebrating another record-breaking season-opening week to confronting its deepest crisis of credibility since the Tim Donaghy officiating scandal. A federal indictment has now tied active players, a head coach, and organized crime figures to a sprawling gambling conspiracy. For a league that spent the past decade embracing sports betting as part of its commercial strategy, this is no longer a public relations problem. It is an existential one. And that means one thing: Adam Silver must now govern like a compliance officer, not a marketer.

The Commissioner’s Crossroads

Adam Silver’s leadership has always been defined by calm rationality and consensus-building, the antithesis of David Stern’s authoritarian decisiveness. That style worked well during the NBA’s globalization boom and its progressive cultural era. But this moment demands something different: urgency, accountability, and structural reform. The NYT reported that the NBA has begun a review of its policies and procedures, which were clearly inadequate for the situation.

Eric Koreen, writing in  The Athletic, said, Silver faces ‘the league’s biggest credibility issue in at least two decades”. His challenge is to walk a tightrope between patience and justice, acting decisively without overreaching, restoring trust without alienating players and owners. The league’s relationship with gambling partners, its governance model, and its disciplinary framework are all now under scrutiny.

The key question: Can Adam Silver act as both steward of the game and enforcer of its ethics?

1. Recognize the Scope of the Problem

Silver’s first task is to stop treating the scandal as a series of isolated events. As Nate Silver noted in Silver Bulletin, the vulnerabilities are structural; “the NBA is particularly susceptible to cheating based on inside knowledge of player availability”. Prop bets, load management, and tanking have created a shadow economy of insider information that blends seamlessly into the legalized betting marketplace.

This is not just about Terry Rozier’s “fake injury” game or Chauncey Billups’ alleged poker ring. It’s about a league whose financial ecosystem and culture have become dependent on gambling exposure. It’s about the business model itself. Compliance professionals will recognize this dynamic: when the core of your revenue strategy intersects with the core of your risk profile, you do not have a program problem, you have a governance problem.

2. Strengthen Information Governance

This crisis is about information. The NBA’s integrity crisis began with a failure to manage information effectively. Player availability, injury reports, and lineup changes are now tradeable assets in the betting marketplace. As Nate Silver observed, even minor leaks about “who’s actually playing” can swing point spreads by eight or more points. That’s the equivalent of non-public material information in the securities world. In corporate terms, this is MNPI, Material Non-Public Information, and it must be treated with the same rigor as insider trading data. Here are some steps the NBA must implement:

  • Tightened disclosure protocols: Require that injury and lineup information be filed within one hour of a team’s decision, with fines for noncompliance.
  • Digital access controls: Limit and log who within each team can access confidential player data.
  • Independent data audits: Just as SOX audits test financial controls, the NBA needs integrity audits on injury disclosure and betting irregularities.

The league must establish a compliance-grade information governance system, not a PR-based injury reporting mechanism.

3. Redefine the League’s Relationship with Sportsbooks

Silver’s visionary 2014 op-ed in The New York Times helped legalize sports betting in the U.S. But that success has come full circle. The NBA is now “inextricably tied to the alleged behavior,” as Koreen bluntly put it. To restore credibility, Silver must impose a firewall between integrity and revenue, similar to how compliance departments maintain independence from sales in regulated industries. Specific steps include:

  • Eliminating player-specific prop bets, which even industry insiders like Nate Silver identify as “inherently more subject to manipulation”.
  • Revising sponsorship structures, ensuring that betting companies can’t advertise on game broadcasts while the league investigates integrity risks.
  • Creating a Gambling Integrity Council, comprising league officials, compliance experts, and independent regulators, to review data-sharing protocols and monitor suspicious patterns.

Suppose the NBA continues to profit from gambling partnerships while claiming to protect the game’s purity. In that case, it risks the same credibility collapse that befell financial institutions during the 2008 crisis, when compliance was reported to serve profit.

4. Rebuild the Culture of Integrity

At its core, this scandal is not about technology or regulation; rather, it is about culture. The NBA’s locker room culture, as Danny Chau argued in The Ringer, was shaped by “a league that has normalized the gambling impulse under the guise of fan engagement”. Players now live in a universe where betting odds appear on broadcast screens, team apps link directly to sportsbooks, and performance data doubles as betting fodder.

To change this, the NBA must embed compliance education into player development from day one. Rookie orientation should include mandatory integrity training that covers gambling ethics, data confidentiality, and behavioral risks, just as financial firms train new analysts on insider trading.

Moreover, players need a Speak-Up Culture. The league should expand its anonymous hotline system into a comprehensive integrity platform, enabling players, staff, and referees to report suspicious betting behavior confidentially and without fear of retaliation. In compliance terms, culture eats code for breakfast. If the NBA wants to protect the game, it must rebuild a culture that values integrity as much as it values victory.

5. Reform Enforcement and Transparency

Silver now faces his “David Stern moment.” In 2007, Stern responded to the Tim Donaghy scandal with swift discipline, public accountability, and systemic change. Silver’s reputation for diplomacy is an asset in negotiations, but in enforcement, it can look like hesitation.

As Koreen noted, “Silver’s judicious nature has helped put the NBA in a strong financial position… but those were straightforward issues with simple moralities”. This one isn’t. This is about the soul of the league. To restore trust, the NBA should commit to:

  • Independent oversight of the investigation, not internal review.
  • Public disciplinary reports that detail findings and remediation steps.
  • Lifetime bans for proven offenders and mandatory ethics rehabilitation programs for lesser infractions.
  • Annual integrity reports, modeled after corporate sustainability or compliance reports, detail investigations, resolutions, and reforms.

Transparency is not weakness; it is the foundation of credibility. Fans don’t need perfection; they need proof that accountability exists.

6. The Compliance Parallel: Learning from Corporate Scandals

The NBA’s predicament mirrors what compliance officers saw after Enron, Wells Fargo, and Boeing: systems designed for performance became blind to integrity. The fix wasn’t more PR; it was embedding ethics into governance. What Silver must build now is not a crisis response team but an Integrity Management System:

  • A structure where compliance is independent.
  • A tone at the top that puts ethics before revenue.
  • A culture that values truth-telling more than brand protection.

The NBA can learn from the financial industry’s compliance architecture post-SOX and Dodd-Frank: independent monitoring, whistleblower protection, and transparency are not burdens; they are safeguards.

7. Restoring the Social License

Beyond regulation and enforcement, Silver must focus on what corporate governance experts refer to as the “social license to operate.” Sports leagues, like corporations, depend on public trust for legitimacy. As Koreen warned, “If people don’t believe your games are fair and your teams are playing by the same rules, then you don’t have much of a league at all”.

That’s the ethical horizon Silver must navigate. Rebuilding trust will take years, but it begins now, with decisive, integrity-centered leadership. The next time fans see an NBA injury update or a sportsbook advertisement, they shouldn’t wonder if the league is complicit in the gamble. They should believe, without hesitation, that the NBA is protecting the game.

Final Thought: Betting on Integrity

The NBA’s crisis is not just a gambling story; it’s a mirror held up to every organization that prioritizes engagement over ethics. For compliance professionals, the message is universal:

Integrity isn’t a cost center. It’s the scoreboard that determines whether your enterprise survives.

If Adam Silver can pivot from expansion to ethics from betting on growth to betting on trust, he will not simply save the league’s reputation. He will redefine what compliance leadership looks like in modern sports. Because in the end, the only wager worth making is on integrity itself.