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Great Women in Compliance

Great Women in Compliance: Why Decision Rubrics Matter in the Age of AI with Hemma Lomax and Shalini Rajoo

In this conversation, GWIC host Dr. Hemma R. Lomax and Shalini Rajoo explore the critical role of decision rubrics in governance, accountability, and trust, especially in the context of AI. Shalini shares her journey from law to compliance, emphasizing the importance of understanding systems and the impact of leadership on decision-making processes. They discuss how transparency and clarity in decision-making can build trust within organizations and the necessity of responsible AI governance. Practical tips for improving decision quality are also provided, highlighting the importance of self-awareness and critical thinking in leadership.

Takeaways:

  • The biggest risk in governance is unclear decisions.
  • AI amplifies existing clarity or confusion in decision-making.
  • Systems and rules reflect the identities of their architects.
  • Everyone has an impact on those around them every day.
  • Leadership is about improving the people around you.
  • It’s not just about rules; it’s about how people behave.
  • Decision rubrics provide consistency and predictability in outcomes.
  • Transparency in decision-making processes builds trust.
  • Slowing down to ask questions can lead to better decision-making.
  • Writing down the reasons for decisions brings clarity and accountability.

Sound bites:

“Systems and rules are not inherently neutral.”

“Transparency in decision making builds trust.”

“Slow is smooth, and smooth is fast.”

Chapters:

00:00 Introduction to Decision Rubrics and Governance

02:55 Shalini’s Journey: From Law to Governance

06:09 The Impact of Systems on Leadership and Accountability

09:09 Transitioning to Compliance and Ethics

11:49 Understanding Decision Rubrics in Compliance

15:06 The Role of Leadership in Decision Making

18:03 Designing Conditions for Effective Decision Making

20:47 The Importance of Transparency in Decision Processes

24:09 Decision Rubrics: Building Trust in Organizations

26:49 AI and Governance: Leadership Infrastructure Failures

29:47 Responsible AI: The Role of Ethics and Compliance

32:55 Practical Tips for Improving Decision Quality

36:00 Conclusion: The Future of Decision Making in AI

Guest Biography:

Shalini Rajoo is the Founder and Principal Consultant of Shalini Rajoo Advisory, LLC, where she partners with organizations to design governance, compliance, and decision-making systems that are resilient, trustworthy, and aligned to real operational pressures. Across more than two decades in law, compliance, HR, and organizational leadership, Shalini has helped companies and leaders move beyond check-the-box frameworks to build structures that embed accountability, clarity, and performance into everyday decisions.

She began her career in South Africa, first as a public prosecutor and then leading regulatory work with the Department of Trade and Industry, collaborating with legislative and executive stakeholders on corporate, competition, and consumer law. After relocating to the U.S., Shalini practiced commercial litigation. She later served as Director of Global Business Conduct for a Fortune 500 company, where she redesigned ethics and compliance systems, led global risk assessments, and championed psychological safety and integrity-based practices.

Today, Shalini’s work centers on helping leaders clarify decision rights, governance architectures, and accountability pathways — especially as organizations adopt AI and automation. She recently spoke at the Opal Group’s Corporate Governance & Ethics in the Age of AI conference, where she reframed AI governance as a leadership-infrastructure challenge rather than a purely technical or compliance one.

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From the Editor's Desk

From the Editor’s Desk – Aaron Nicodemus on the CW AI Conference Insights: Navigating the Practical Use of AI in Compliance

In this episode of ‘From the Editor’s Desk,’ Tom Fox visits with Aaron Nicodemus to discuss highlights from the recent Compliance Week AI Conference. Key takeaways include the importance of understanding the purpose and practical use of AI tools before implementation, the pressures from C-suite and boards to adopt AI, and the necessity of a human-in-the-loop approach. The conversation also touches on integrating trust and integrity into AI adoption, the evolving role of compliance as a trusted partner in AI initiatives, and the collective willingness to learn and apply AI across compliance operations.

Key highlights:

  • Importance of Understanding AI Implementation
  • Pressure from the Top: Compliance and AI
  • Human Oversight in AI Processes
  • Trust and Integrity in AI
  • Compliance as a Competitive Advantage
  • Real-World Examples: Robinhood and DocuSign
  • The Evolving Role of Compliance in AI
  • Conference Vibes and Final Thoughts

Resources:

Aaron Nicodemus on LinkedIn

Compliance Week

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Innovation in Compliance

Innovation in Compliance – The Strategic Evolution of Compliance: Insights from Angie McPhail

Innovation comes in many forms, and compliance professionals need not only to be ready for it but also to embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox welcomes Angie McPhail to discuss the transformation of compliance from a regulatory function to a strategic business imperative.

Angie shares her professional background, having led the Integrity and Compliance group for the Americas at Juniper Networks before its acquisition by HPE. Key discussions include the evolving role of compliance as a strategic influencer within organizations, the intersection of ethics and integrity with ESG, and the importance of trust in building effective compliance programs. Angie emphasizes the need for compliance professionals to understand business strategy, leverage technology, and build trust to drive sustainable growth. The talk also covers the future outlook for compliance leaders and provides advice on preparing the next generation of compliance professionals.

Key highlights:

  • Compliance as a Strategic Business Function
  • Influence and Trust in Compliance
  • Compliance as a Driver of Business Success
  • Managing Reputational Risk
  • Future of Compliance Leadership

Resources:

Angie McPhail on LinkedIn

Innovation in Compliance was recently ranked 4th among Risk Management podcasts by 1,000,000 Podcasts.

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FCPA Compliance Report

FCPA Compliance Report: Navigating Corporate Ethics and Compliance Trends in 2026 with Mike Volkov

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this inaugural episode of 2026, Tom Fox welcomes back his good friend and colleague, Mike Volkov, to reflect on the tumultuous year of 2025 and discuss the new trends for the upcoming year. This is Part 1 of a two-part series.

Highlighting the resilience of corporate ethics amid the suspension of the FCPA, the conversation underscores the necessity for businesses to uphold ethical values, despite regulatory changes. Discussions delve into the importance of demonstrating ethical behavior as a fundamental business value and the growing significance of organizational justice and trust within corporations. Moreover, they address evolving enforcement in areas such as export controls, trade sanctions, and tariff regulations, suggesting a shift toward rigorous compliance in national security matters. This episode provides a comprehensive outlook on the compliance challenges and opportunities for 2026.

Key highlights:

  • Welcome to 2026: A New Beginning
  • The Importance of Ethics in Business
  • Organizational Justice and Trust
  • Generational Perspectives on Ethics
  • Emerging Trends in Trade and Compliance

Resources:

Mike Volkov on LinkedIn

Volkov Law Group

Tom Fox

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SBR - Authors' Podcast

SBR-Authors Podcast: Risk is the Soundtrack of Life with Jim Massey

Welcome to the SBR-Authors Podcast! In this podcast series, Host Tom Fox visits with authors in the compliance arena and beyond. In this episode, Tom Fox welcomes back Jim Massey to discuss Jim’s latest book, ‘Risk in Action: A Leader’s Guide to Clarity.’

They take a deep dive into how the book builds on the themes outlined in ‘Trust in Action,’ focusing on the comprehensive approach to managing risk, trust, and fear. Jim shares insights on redefining risk not as a binary choice but as a polarity to be managed, offering actionable steps for business and compliance leaders. He also introduces his new AI-driven risk assessment tool, designed to provide real-time, actionable insights. Jim emphasizes the importance of embracing risk as an opportunity for innovation and shares his key leadership lessons for navigating the ever-changing business landscape.

Key highlights:

  • The Genesis of ‘Risk in Action’
  • Understanding Risk and Its Importance
  • The Role of Fear in Risk Management
  • Innovative Risk Management Strategies
  • Leadership and Risk
  • The Future of Risk Assessments

Resources:

Risk in Action on Amazon

Jim Massey Website

Jim Massey on LinkedIn

Eastward.ai Website

Tom Fox

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Innovation in Compliance

Innovation in Compliance – Mastering Communication: Insights from Dr. Dennis Cummins on Speaking and Selling without Selling

Innovation comes in many areas, and compliance professionals need to be ready for it and embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, Tom Fox hosts Dr. Dennis Cummins, CEO of Pro Speaker Academy, to discuss the art of speaking and selling without pushing sales.

Dr. Cummins shares his journey from being a successful chiropractor to a professional speaker and trainer, emphasizing the importance of effective communication in corporate settings. They explore the connections between speaking, selling, compliance, and internal communication, highlighting how clear and compelling communication can foster a better corporate culture and increased engagement. Dr. Cummins also introduces concepts such as ‘invitational selling’ and the power of storytelling in business. The episode concludes with details about Dr. Cummins’ latest book, ‘Non-Professional Speaking,’ and his upcoming event, ‘Building Your Business from the Stage. ‘

Key highlights:

  • Dennis Cummins’ Professional Journey
  • The Importance of Communication in Corporations
  • Invitational Selling Explained
  • The Power of Storytelling
  • The Danger of Unscripted Moments
  • Building Trust Through Clear Speaking
  • Upcoming Event: Building Your Business from the Stage
  • Writing Non-Professional Speaking

Resources:

Non-Professionally Speaking: How Professionals Turn Small Talks Into Big Profits on Amazon

Visit Dr. Dennis Cummins’ Website

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Link to Speaker Demo Video

Tom Fox

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12 O’Clock High-a podcast on business leadership

12 O’Clock High, A Podcast on Business Leadership – Building Trust and Relationships: The Power of Compliance and Ethics with Jacqui Pruet

12 O’Clock High, an award-winning podcast on business leadership, brings together stories from history, the arts, sports, movies, research, and current events to consider leadership lessons. In this episode, Tom Fox interviews Jacqui Pruet, founder of A. C. E. Austin Compliance & Ethics Professional.

Pruet shares her journey of creating ACE to address the lack of local networking opportunities for compliance professionals in Austin, Texas. She discusses her passion for ethics and compliance, stemming from her background as a state regulator and strategist, as well as her innovative approach to building high-trust leadership communities. Pruet emphasizes the importance of relationships and trust in compliance, sharing insights on how effective compliance can drive business efficiency and profitability. She also explores the evolving alignment between innovation, governance, and compliance, and discusses how her regulatory background gives her a unique perspective in the compliance field.

Key highlights:

  • Jacqui Pruet’s Journey to Founding ACE
  • The Importance of Compliance and Ethics
  • Executing the Vision of ACE
  • High-Trust Leadership Communities
  • Confidentiality and Trust in Leadership
  • Building Relationships and Trust
  • Revenue and Ethics: A Strategic Advantage
  • Regulatory Background and Compliance Strategy

Resources:

Jacqui Pruet on LinkedIn

Tom Fox

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Blog

The Roots of Compliance: Trust, Technology, and the Future of Banking

Recently, I had the opportunity to visit with John Byrne, the CEO at Corlytics. You can listen to the podcast here. One of the more interesting topics we discussed is that compliance professionals find themselves at the intriguing crossroads between groundbreaking technological innovation and the timeless, foundational principles of compliance, notably trust and integrity. Nowhere is this more evident than in the banking sector, where the stakes around trust are extraordinarily high. Now, with the Trump Administration actively promoting cryptocurrency to both the US banking industry and the American public, that foundational principle is even more critical.

Historically, banking, with over two and a half centuries of operational legacy, has always relied fundamentally on customer trust. Indeed, long before modern regulatory structures emerged, banks implemented internal policies and compliance-like practices designed explicitly to instill and maintain confidence. Yet despite advancements in regulation and technology, the principle remains unchanged: trust is the lifeblood of banking, and when it falters, the consequences can be catastrophic.

Nothing illustrates this more starkly than the old-fashioned bank run, perhaps the ultimate demonstration of breached trust. In a bank run, customers simultaneously lose faith in the institution’s ability to safeguard their assets, rushing en masse to withdraw funds. This panic-driven action rapidly transforms initial doubt into widespread fear, creating an accelerating cascade effect that can swiftly collapse even seemingly robust institutions.

The recent 2023 examples of Silicon Valley Bank, Signature Bank, and First Republic Bank, all headquartered in California, underscore this timeless truth. Despite occurring in a digitally connected world with instantaneous communication, the root cause was identical to that of traditional bank runs, famously depicted in classic movies like Mary Poppins and It’s a Wonderful Life: a fundamental failure of trust. For today’s compliance professionals, the lesson remains clear and resonant. Even as they harness modern tools like artificial intelligence to enhance compliance processes, they must remain ever-vigilant custodians of trust, recognizing that without it, all technological advances and regulatory structures are ultimately insufficient to protect a bank, and indeed any business, from the devastating impact of lost confidence.

Lesson 1: Trust is the Foundation of Compliance

The essence of compliance has always been rooted in trust. Banking, as a sector with over 250 years of history, exemplifies this principle vividly. Long before the regulatory frameworks we recognize today, banks operated with internal policies designed to cultivate and maintain trust with their customers. Compliance, in its earliest incarnation, was about establishing clear standards and rules internally, ensuring customer confidence and institutional stability.

Today, despite the extensive web of external regulations, trust remains a central concern. The collapse of trust can trigger catastrophic outcomes, vividly illustrated by historical bank runs such as those portrayed in classic films like Mary Poppins and It’s a Wonderful Life. Even as recently as 2023, the failure of Silicon Valley Bank in California, a modern-day bank run accelerated by technology, reminds us starkly how fragile trust can be and how critical it remains for compliance professionals to safeguard it diligently.

Lesson 2: Compliance is Good Business

The notion of compliance as a hindrance to business, often unfairly labeled as the “business prevention unit,” is shifting dramatically. A sound compliance program aligns closely with strong business outcomes —a principle that has been repeatedly emphasized in recent years. Banks and businesses are increasingly recognizing compliance not as an obstacle but as an integral part of strategic business operations.

Good compliance facilitates a trustworthy reputation, ensures customer satisfaction, and establishes long-term business stability. Firms that embody compliance as a core business strategy consistently demonstrate resilience and sustainability. Compliance isn’t merely a regulatory necessity; it is fundamentally good business.

Lesson 3: Regulation Should Complement, Not Replace, Internal Standards

Historically, banks created their internal compliance measures to protect their institutions long before external regulation mandated such frameworks. Over time, regulatory developments have supplemented and formalized these practices, creating a structured external governance model. However, prudent banks continue to adhere to high internal standards irrespective of regulatory mandates.

Effective compliance frameworks seamlessly integrate internal ethical guidelines and external regulatory requirements, ensuring a unified approach to governance. Organizations shouldn’t solely rely on external regulations to dictate their ethical and operational standards. Instead, compliance professionals should encourage internal benchmarks of ethical behavior and trustworthiness, aligning company culture closely with compliance objectives to achieve sustainable business excellence.

Lesson 4: Technology as an Enabler of Efficient Compliance

One common complaint about compliance is its perceived inefficiency, which businesses argue slows down operations. Here, advanced technology, especially AI, presents transformative possibilities. AI-driven tools can significantly streamline compliance processes, enhancing speed, efficiency, and accuracy.

AI technologies allow compliance teams to swiftly identify risks, maintain comprehensive documentation, provide clear audit trails, and escalate issues rapidly and accurately. Rather than viewing technology as complicating compliance, companies should embrace it as an essential tool enabling compliance professionals to focus on strategic, high-value tasks rather than routine manual processes. This technological enablement does not replace skilled compliance professionals. It enhances their capabilities, ensuring more effective outcomes for the business as a whole.

Lesson 5: Compliance Should Be Proactive, Not Reactive

Compliance practices should always be forward-looking and proactive, anticipating potential issues and acting accordingly. Banks and businesses that are successful in managing risk and maintaining trust have learned not to wait for regulators to dictate ethical standards. They proactively implement robust compliance and governance frameworks because they recognize that doing the right thing is inherently good for business.

Proactive compliance fosters customer trust, internal coherence, and institutional resilience. It positions companies to avoid reputational and financial harm, reducing the likelihood of regulatory actions or scandals. Compliance professionals must champion a proactive approach, integrating ethics and integrity at every organizational level, ensuring firms remain compliant and trustworthy, irrespective of whether regulatory bodies explicitly require it.

Conclusion: A Sustainable Business Model Through Good Compliance

The future of compliance in banking, and indeed all industries, rests at the intersection of timeless principles and modern technology. Trust, always the cornerstone of compliance, remains a foundational element. Technology, particularly artificial intelligence (AI), offers powerful new tools to reinforce and streamline compliance functions, enabling more efficient, accurate, and effective oversight.

Compliance professionals stand at the threshold of an exciting era where they can leverage advanced technologies to reinforce and extend the timeless principle of trust. By returning to the roots of compliance, embedding trust deeply into corporate culture, and embracing technology as a powerful enabler, businesses will not only fulfill regulatory requirements but also establish a resilient, customer-centric, and sustainably profitable business model. Compliance, done right, transcends its role as merely regulatory adherence. It becomes a fundamental pillar of sound business practice.

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Blog

The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early developments. (A copy of her remarks can be found here.) There was also updated information on the DOJ approach to whistleblowers and anti-retaliation found in the 2024 Update to the Evaluation of Corporate Compliance Programs (2024 ECCP). She addressed the growing importance of using data analytics to evaluate key aspects of a company’s corporate culture, particularly employee engagement, trust, and overall corporate ethics.

Assessing corporate culture is essential for compliance professionals. Culture is a powerful determinant of whether employees will adhere to company policies, report misconduct, and act ethically. The DOJ has made it clear through the 2024 ECCP that an organization’s culture of compliance is as critical as the controls themselves. Compliance programs must go beyond preventing misconduct and cultivate a culture where ethics and transparency are prioritized.

Employee engagement and trust are at the heart of this culture. Engaged employees are more likely to comply with rules and report issues. However, if there is a lack of trust—whether in the company’s leadership, policies, or reporting mechanisms—the risk of ethical lapses and misconduct increases. Data analytics can offer compliance professionals actionable insights into these hard-to-measure elements of corporate culture.

Leveraging Data Analytics for Cultural Insights

Traditionally, companies have relied on surveys, focus groups, and audits to assess employee engagement and trust. Despite their value, these methods frequently have limitations due to low response rates, biases, and a point-in-time perspective. On the other hand, data analytics offers ongoing, real-time insights across various indicators. Let’s explore how data analytics can help evaluate employee engagement, trust, and corporate culture:

Employee Engagement Data

Employee engagement can be a key indicator of whether a compliance program is likely to succeed. High levels of engagement suggest that employees are motivated, aligned with corporate values, and likely to act in the company’s best interest.

Metrics to Consider

  • Employee Feedback Platforms. Tracking data from feedback platforms (such as pulse surveys or anonymous feedback tools) can provide insights into employee sentiment about their work environment and leadership.
  • Participation in Training Programs. Data on employee participation in compliance training—especially voluntary programs—can offer insights into employees’ engagement with the company’s compliance initiatives.
  • Use of Corporate Tools. Monitoring internal systems such as compliance hotlines, whistleblower portals, and internal messaging boards can help assess whether employees feel empowered to engage with compliance resources.

By monitoring engagement trends over time, compliance officers can detect shifts in employee engagement and intervene if levels drop. For instance, increasing non-compliance with mandatory training could be a red flag for broader cultural issues.

Trust in Leadership and Compliance Programs

Trust is a critical component of a successful corporate compliance culture. If employees do not trust leadership or the compliance function, they are less likely to report misconduct and more likely to turn a blind eye to ethical violations.

Metrics to Consider

  • Whistleblower Reporting. Data on the number of whistleblower reports can be telling. A lack of reports may not necessarily indicate a lack of issues—it could signal a fear of retaliation or distrust in the reporting process.
  • Retention Rates in High-Risk Areas. Monitoring employee turnover in areas that are considered high-risk (e.g., finance, procurement, or overseas offices) can help determine whether ethical concerns are driving departures.
  • Survey Data on Trust Levels. Regular employee surveys on perceptions of leadership and the compliance program can offer a pulse on trust. The key is to go beyond traditional engagement surveys and ask questions about ethical concerns and trust in compliance leadership.

Combining survey data with data from whistleblower systems and employee retention analytics can offer a more nuanced view of whether employees trust leadership. A low reporting rate and high turnover in high-risk areas may indicate deeper cultural problems requiring intervention.

Monitoring Employee Behavior and Risk Indicators

One of the most significant ways data analytics can support compliance efforts is by detecting behavioral patterns that may indicate a lapse in corporate culture or potential compliance risks.

Metrics to Consider

  • Expense and Travel Data. Analyzing expense reports and travel data patterns can reveal inconsistencies or potential misconduct, such as fraudulent claims or unauthorized spending.
  • Email and Communication Analysis. Some companies use natural language processing (NLP) tools to analyze internal communications for warning signs of ethical issues. This can include detecting language that suggests rule-breaking, covering up misconduct, or expressing discontent with corporate policies.
  • Business Unit Performance vs. Compliance Reporting. Comparing performance data across business units with the frequency of compliance-related issues can provide insights into whether high-performing units are cutting corners to achieve their results.

Behavioral analytics can help compliance professionals detect patterns before they escalate into larger issues. For example, if a particular business unit shows exceptional financial performance but is under-reporting compliance concerns, this could signal a risky culture of non-compliance.

Driving a Data-Driven Culture of Compliance

Implementing data analytics in your compliance program requires the right technology, processes, and, most importantly, corporate buy-in. As the DOJ highlighted in its recent updates to the 2024 ECCP, compliance personnel must have adequate access to relevant data sources and the resources to interpret and act on that data. Companies should invest in the same level of technology for their compliance functions as they do for their business operations.

Some of the keys every compliance program should consider to help implement a data-driven culture of compliance include the following strategies:.

  • Build Cross-Functional Partnerships. Compliance teams should collaborate with human resources, IT, and business operations to gain access to the data they need. A cross-functional approach ensures compliance data is integrated into the company’s broader performance metrics.
  • Foster Transparency in Data Use. Be clear with employees about how their data will be used, particularly in sensitive areas such as monitoring communication. Emphasizing the ethical use of data can help build trust.
  • Regularly Reassess Your Metrics. As with any compliance program, the metrics used to evaluate corporate culture should evolve. New risks, technologies, and business challenges should inform your data strategy.

Strengthening Compliance through Analytics

The DOJ made clear in the Argentieri speech and the 2024 Update to the Evaluation of Corporate Compliance Programs that a data-driven approach to understanding employee engagement, trust, and corporate culture is essential for compliance success. Data analytics offers compliance professionals powerful tools to assess whether employees are following the rules and truly engaged in creating an ethical and compliant corporate environment.

As we look toward the future, companies prioritizing data analytics in their compliance programs will be better equipped to prevent misconduct, identify cultural risks, and foster a workplace that values ethics and transparency. For compliance officers, the time is now to embrace data analytics and use it to reinforce the foundation of a strong corporate compliance program.

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Compliance Tip of the Day

Compliance Tip of the Day: Employee Trust

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, our aim is to provide you with 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.

In this episode, we consider how you can work to regain employee trust in the era of remote work and RTO.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.