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Compliance Into the Weeds

Compliance into the Weeds: Global Anti-Corruption Leadership

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 episode, Tom Fox and Matt Kelly are joined by Mary Inman, a founding partner at Whistleblower Partners.

Matt, Tom, and Mary reflect on the global response to anti-corruption measures following an executive order issued by former President Trump. The conversation highlights webinars conducted in early 2025 that addressed concerns over who would enforce anti-corruption laws worldwide if the United States stepped back. The sentiment among countries like Brazil, Hong Kong, Singapore, England, and France was clear; they were ready to take on the mantle themselves.

Mary reports on her conversations with the SFO in London about instituting a whistleblower program and similar initiatives in the United Kingdom at His Majesty’s Revenue and Customs and the Financial Conduct Authority.

Key highlights:

  • Global Anti-Corruption Sentiment Post-Trump’s Executive Order
  • Encouraging International Enforcement
  • Evidence of Global Enforcement Actions
  • Whistleblower Incentives in the UK
  • Global Leadership in Anti-Corruption

Resources:

Mary Inman on LinkedIn

Whistleblower Partners

Matt in Radical Compliance 

Tom

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

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Compliance Tip of the Day

Compliance Tip of the Day – AI for Whistleblower Anonymity

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 look at how to harness AI for whistleblower anonymity and incident management.

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Blog

AI Game-Changing Compliance: Part 4, AI Can Improve Whistleblower Response

Whistleblower programs have long been a cornerstone of corporate compliance, providing employees and stakeholders with a crucial mechanism to report misconduct, fraud, and ethical violations. However, whistleblower response programs in many organizations remain burdened by slow triage processes, an overwhelming volume of reports, and inconsistent follow-ups. The result? Potentially high-risk cases get lost in the shuffle, and employees lose confidence in the system, sometimes opting to go straight to regulators instead of utilizing internal reporting channels. AI-powered tools allow compliance teams to cut through the noise, identify patterns of misconduct, and proactively address risks before they escalate into regulatory or reputational disasters.

Lessons Learned for Compliance Professionals

Integrating cutting-edge technology with traditional investigative methods has ushered in a new era of efficiency and precision in addressing internal concerns. By harnessing advanced analytics, organizations can speed up case prioritization while maintaining essential human oversight. The following five lessons provide strategic insights into how AI can be optimally deployed to enhance whistleblower response times and streamline investigations.

1. Leveraging AI to Augment Strategic Decision-Making Capabilities

When discussing AI in whistleblower response and investigations, it’s imperative to understand that these advanced tools are a force multiplier for human expertise. AI systems can rapidly sift through vast volumes of data and flag anomalies and surface patterns that might otherwise go unnoticed. However, as any seasoned compliance professional will attest, context is king. While highly valuable, AI-generated alerts must be interpreted within the nuances of organizational culture, legal frameworks, and human behavior. This is where human judgment becomes indispensable.

Consider a scenario in which an AI system identifies a cluster of complaints that could suggest systemic misconduct. The tool might rank these cases by urgency, yet the final decision on how to proceed rests on experienced eyes that can assess subtle cues and contextual factors. This hybrid approach ensures that the investigative process is both swift and accurate. Human oversight can identify when an AI might be overzealous or missing context-specific insights, thus better calibrating the technology to suit the organization’s compliance needs.

2. Expedited, Transparent, and Data-Driven Whistleblower Response Frameworks

Various laws and regulatory requirements mandate that organizations react swiftly to whistleblower reports. With AI-driven systems, compliance teams can dramatically reduce the lag between submitting a report and initiating an investigation. Traditional manual processes might delay the evaluation, leading to enhanced regulatory scrutiny, fines, or significant reputational harm. AI-powered platforms can immediately triage the report, cross-reference it with existing data, and prioritize cases based on risk and historical patterns. This level of responsiveness not only meets the high expectations of regulators but also reinforces internal trust in the organization’s commitment to ethical conduct.

Transparency is another key facet. AI systems can log every step of the investigative process, creating an audit trail that is accessible for internal reviews and regulatory inspections alike. Such transparency is invaluable, demonstrating that the organization is serious about addressing compliance concerns in real-time. When employees see that their reports are acted upon swiftly and openly, it cultivates an environment of trust and accountability.

3. Leveraging Diverse Data Sets  

One of the most critical lessons for compliance professionals leveraging AI in whistleblower investigations is the need for diversity in the data used to train these systems. AI is only as unbiased as the information it learns from. When processing sensitive whistleblower reports, any embedded bias can lead to unfair prioritization, potentially skewing investigations and undermining trust in the system.

Your AI tool should be continuously refined with diverse datasets representing various employee backgrounds, complaint types, and contextual factors. This practice ensures that the algorithms can handle the varied nature of whistleblower reports without favoring or penalizing any group or type of complaint. Compliance professionals should work closely with data scientists to conduct regular audits of AI outputs, ensuring the system’s decisions remain equitable and legally sound.

4. Fortifying Employee Confidence Within the Whistleblower Ecosystem

Building a robust and responsive whistleblower system is not about the technology. Rather, it is about fostering trust among employees. AI-driven systems can significantly enhance transparency and timeliness, but without employee buy-in, even the most sophisticated platform will fall short. When employees trust their concerns will be addressed promptly and fairly, they’re more likely to report issues internally rather than taking their concerns to external regulators, which can be more damaging to the organization’s reputation and finances.

AI’s role in this equation is pivotal. By automating the initial stages of case triage and providing real-time updates on the status of investigations, AI ensures that whistleblower reports are not lost in bureaucratic limbo. This immediacy reinforces the message that the organization is committed to addressing issues as they arise. The transparency AI systems offer—through comprehensive audit trails and clear reporting metrics—provides employees with tangible evidence that their voices are heard.

5. Elevating Stakeholder Confidence 

While the initial investment in AI-driven whistleblower systems may seem steep, the long-term benefits, especially cost savings, are substantial. One of the key lessons for compliance professionals is that the deployment of AI is not merely a technological upgrade; it is a strategic decision that can transform the financial landscape of compliance operations. AI streamlines the investigative process by reducing the time to sift through and prioritize whistleblower reports, cutting down on labor-intensive tasks that often drive up costs.

By automating routine processes, organizations can reallocate human resources to more complex issues that require nuanced judgment. This speeds up the response time and minimizes the risk of costly errors or oversights that could lead to regulatory fines and legal liabilities. The efficiency gains from AI-driven investigations often translate into fewer disruptions and lower operational costs. For example, when a potential compliance issue is flagged and resolved promptly, the organization avoids the cascading expenses associated with prolonged investigations, legal battles, and reputational damage.

In addition, the transparency and accuracy provided by AI systems can serve as a form of risk mitigation. Detailed audit trails and systematic data analysis ensure that every step of the investigative process is documented, providing a solid defense in the event of regulatory scrutiny. This comprehensive documentation can be a lifesaver during audits, saving time and legal fees. Ultimately, while the upfront costs of AI implementation should be weighed, the return on investment is clear: faster, more efficient investigations lead to lower compliance costs, a stronger legal standing, and a healthier corporate reputation. In today’s high-stakes regulatory environment, AI is not just a tool—it’s a long-term financial strategy that benefits the organization’s bottom line and integrity.

The Future is Here: How AI Enhances Whistleblower Response and Investigations

In “Artificial Intelligence and Whistleblowing: Can A.I. be Useful for Whistleblowing Processes?” Kalliopi Zouvia detailed the evolving relationship between whistleblower protection and artificial intelligence. She reviews the emerging role of AI in strengthening mechanisms for detecting, reporting, and investigating unethical practices, making it a vital read for corporate compliance professionals seeking to harness technology in upholding ethical standards.

She reviews key milestones, including Council of Europe recommendations and, more recently, the EU’s Whistleblower Directive (Directive 2019/1937), which sets a standardized baseline for protecting individuals across the EU. For corporate compliance officers, understanding these regulatory benchmarks is essential for designing internal policies that comply with legal mandates and foster a culture of transparency and accountability. Central to the discussion is the three-tier reporting model outlined by the Directive, which offers multiple channels for whistleblowers to report concerns—internally, externally, to competent authorities, or, ultimately, publicly via the media. Confidentiality and, where possible, anonymity remain crucial elements, ensuring that the identity of the reporting individual is safeguarded against unnecessary disclosure. While providing flexibility, this model also imposes significant operational challenges on organizations tasked with responding swiftly and effectively to such reports.

A major focus of the article is the potential of artificial intelligence to enhance each stage of the whistleblowing process. AI-driven reporting systems, such as chatbots, are highlighted as powerful tools that can guide individuals through the reporting process, reducing the likelihood of incomplete submissions and providing simple instructions about reporting requirements. Real-time translation services powered by AI can break down language barriers, broadening access to reporting channels across diverse cultural and ethnic groups, a critical factor for multinational corporations committed to global ethical standards.

Beyond the initial report submission, AI shows promise in streamlining the vetting and investigative processes. Automated data extraction and advanced analytics can sift through vast amounts of information to isolate relevant details, significantly reducing the manual burden on compliance teams. This technology speeds up the preliminary review of allegations and helps identify patterns or red flags that may show deeper systemic issues. Such efficiencies are valuable considering increasing report volumes, as evidenced by European and American whistleblowing statistics trends.

AI-driven whistleblower response programs are no longer futuristic concepts but essential tools for modern compliance teams. By integrating AI into whistleblower programs, companies can prioritize high-risk cases, accelerate investigations, enhance transparency, and protect whistleblowers from retaliation. As regulatory bodies continue emphasizing whistleblower protections, organizations that fail to modernize their response programs risk falling behind in compliance maturity and exposing themselves to legal and reputational risks.

The call to action for compliance professionals is clear: Embrace AI-driven whistleblower programs now or risk facing regulatory scrutiny later. The technology is available, the benefits are measurable, and the time to act is now.

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Compliance Tip of the Day

Compliance Tip of the Day: The Wolf Man and Supporting Whistleblowers

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.

How does the Wolf Man’s story inform how you should treat whistleblowers?

 

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Great Women in Compliance

Great Women in Compliance: Mary Inman and Jane Norberg on Current Developments in Whistleblower Laws and Practice

Welcome to the Great Women in Compliance podcast with Hemma Lomax and Lisa Fine, sponsored by Corporate Compliance Insights.  Over the past few months, the Department of Justice put forth the Whistleblower Pilot Program, and the update to the Evaluation of Corporate Compliance Programs.  It was the perfect time to focus on how these impact whistleblower laws. Jane Norberg, who is a partner at Arnold & Porter and the former Chief of the Office of the Whistleblower and Mary Inman, who is a founding partner of Whistleblower Partners. Mary is also an advocate for the power of whistleblowers and is known for representing Facebook Files whistleblower Frances Haugen and Theranos whistleblower Tyler Shultz.

They provide insight into what makes a credible and legitimate whistleblower, how the SEC reviews tips from whistleblowers and what we as compliance professionals can do to build effective programs. All focused on the review of all concerns that are raised, regardless of the source. They provide some thoughts about how to handle different situations before, during, and after an investigation, providing practical advice.

The group discusses the new DOJ Whistleblower Pilot program and where it follows the past programs like the SEC program and where it is filling new gaps. One part of the program includes the 120-day requirement for reporting an issue, and they focused on what that would mean for organizations. Mary and Jane share their views on the requirements and the best practices and reference how most compliance professionals are using the DOJ Evaluation of Corporate Compliance to develop their programs, which means that an issue is investigated. In practical terms, following the ECCP requirement to investigate, and the pilot program has a “race to report,” is a challenge, and this is discussed in depth.

Mary and Jane both provided “one thing you should know” to conclude the discussion. Both points are significant ones for anyone who is dealing with any point of the whistleblower or building a strong speak up/anti-retaliation culture.

Join the Great Women in Compliance community on LinkedIn here.

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Blog

Navigating Compliance in Interesting Times

I once had a boss whose catchphrase was, ‘May you live in interesting times.’ That applied back in the first decade of this century and is even more appropriate now. In a world that often feels like it is constantly shifting beneath our feet, the role of the corporate compliance professional has never been more crucial or challenging. In recent New York City Bar Association Compliance Institute remarks, Principal Associate Deputy Attorney General Marshall Miller offered timely insights on the Department of Justice’s (DOJ) evolving approach to corporate criminal enforcement. His message was that compliance professionals are essential to organizational success, national security, and the broader rule of law.

  • Individual Accountability as the Cornerstone of Corporate Compliance

Miller emphasized that individual accountability remains a primary focus of the DOJ’s corporate criminal enforcement. According to Miller, they are prosecuting individuals at the top or throughout the corporate hierarchy, as it sends a strong message that misconduct is not tolerated and reinforces deterrence across the board.

For compliance officers, this focus on individual accountability reinforces the importance of training and awareness programs that help employees understand the personal stakes of unethical behavior. Compliance programs must communicate that misconduct has consequences for the organization and those directly involved.

This means compliance professionals should regularly update training modules to reinforce the personal consequences of non-compliance. Consider scenarios that show employees how individual misconduct can lead to legal repercussions, strengthening the deterrence message.

  • Transparency and Consistency in Enforcement Policies

One of the most significant updates shared by Miller is the DOJ’s emphasis on clarity, consistency, and predictability across its corporate enforcement policies. In past years, self-reporting or cooperating with investigations was often perceived as a gamble. Today, under new DOJ guidelines, a clear framework outlines expectations, rewards cooperation, and even encourages voluntary self-disclosure of misconduct.

This transparency is a game-changer for compliance professionals, who often need concrete examples and assurances to secure buy-in from executives and board members. Compliance leaders can now present a more straightforward business case for ethical behavior, outlining the risks of non-compliance and the potential benefits of self-disclosure.

Every corporate compliance function should leverage the DOJ’s published guidelines to develop a compliance strategy that aligns with the DOJ’s expectations. Create resources for your leadership team that show the tangible benefits of voluntary self-disclosure, including reduced penalties and favorable resolutions.

  • Empowering Whistleblowers and Enhancing Self-Disclosure Programs

Miller announced the launch of a new two-part DOJ whistleblower program that provides different rules and incentives based on whether the whistleblower was involved in criminal conduct. For those not involved, a DOJ awards program now provides a percentage of forfeited funds to the whistleblower. For those involved, whistleblower non-prosecution agreements are available.

This change holds significant implications for compliance programs. Whistleblower protection and incentive structures must be communicated and properly managed, ensuring employees know their rights and the benefits of reporting unethical behavior. With DOJ’s strong support, compliance leaders can strengthen whistleblower protections and encourage a culture of transparency.

Expanding whistleblower training and reporting channels to reflect the DOJ’s updated stance would be best. Emphasize protection and incentivization and ensure employees understand how these policies can benefit them if they report wrongdoing.

  • The Role of Incentives and Compensation Clawbacks in Compliance

The DOJ’s updated compliance approach emphasizes the role of compensation structures in promoting compliance or enabling unethical behavior. DOJ now evaluates incentive structures as part of every criminal resolution, rewarding companies that utilize clawbacks when executives are involved in misconduct.

For compliance professionals, this focus on compensation is an opportunity to align reward structures with ethical performance. Compliance officers can work with human resources to design and implement compensation plans that deter risky behavior by incorporating elements such as escrow accounts for bonuses and clawback provisions for executives involved in wrongdoing.

This means every corporate compliance function and personnel should collaborate with HR to develop compensation structures that support compliance goals, such as incorporating ethical behavior as a performance metric or establishing escrow accounts that hold bonuses contingent on compliance-related performance.

  • Strengthening Governance Structures for Accountability

Miller’s remarks also underscore the need for solid governance frameworks that prevent misconduct from slipping through the cracks. Accountability measures, from board oversight to compliance committee functions, ensure corporate misconduct is detected early and handled appropriately. He noted that companies with rigorous internal governance structures and compliance frameworks are more likely to avoid criminal charges.

For compliance leaders, this means assessing and strengthening their organization’s governance structures to support effective oversight. It also means advocating for periodic audits, third-party evaluations, and regular reviews of compliance policies to keep governance on track. Conduct a governance review to identify potential gaps in oversight and ensure that compliance officers have the authority to raise concerns without interference. Advocate for regular compliance audits and policy updates to keep pace with regulatory developments.

  • Preparing for Emerging Risks Related to National Security and Technology

Miller highlighted increasing corporate criminal investigations involving national security, particularly in the construction, agriculture, telecommunications, and technology sectors. Fueled by sanctions evasion and emerging technologies like artificial intelligence, national security risks are now a major focal point for the DOJ.

Compliance programs need to reflect this shift. Compliance professionals must prioritize emerging risks, especially cybersecurity, AI, and national security. Integrating these areas into the broader compliance program ensures that companies are prepared for the expanding scope of corporate crime.

You should update risk assessments to include national security risks and develop response plans for data security, sanctions compliance, and AI ethics. Equip your compliance team to monitor these evolving threats through specialized training and cross-functional collaboration.

  • A Call to Compliance Professionals: The Business Case for Compliance

Miller concluded with a direct call to compliance professionals, emphasizing the DOJ’s commitment to empowering compliance leaders to advance corporate ethics and compliance. He stressed the importance of making a compelling business case for compliance, using DOJ’s guidelines to advocate for investment in robust compliance programs.

In today’s regulatory environment, compliance is a strategic advantage, not a cost center. Compliance officers must seize this moment to champion the business case for ethics, highlighting the DOJ’s transparent policies and the tangible benefits of voluntary self-disclosure, cooperation, and strong compliance frameworks.

Position your compliance program as an essential part of your business strategy. Use DOJ’s new approach as a lever to secure greater resources and authority, demonstrating that investing in compliance can directly impact organizational resilience and profitability.

  • Final Thoughts

Principal Associate Deputy Attorney General Marshall Miller’s remarks signal a turning point for compliance professionals, who are no longer seen as gatekeepers but as strategic partners in risk management and national security. With the DOJ’s commitment to transparent enforcement policies, expanded whistleblower incentives, and a stronger emphasis on accountability, compliance officers have a clear mandate to champion ethical business practices.

These changes offer a roadmap for compliance leaders to build stronger programs that protect their organizations and reinforce their role as trusted advisors in corporate governance. By adopting the DOJ’s updated principles, compliance professionals can safeguard their organizations, enhance their credibility, and make a compelling case for a proactive approach to corporate ethics.

In our “interesting times,” compliance is no longer just about rules and regulations. It is about building an integrity culture that benefits the organization and the broader community.

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Blog

Supporting Whistleblowers: Lessons from Lon Chaney’s The Wolfman

Ed. Note: This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Today, we use Lon Chaney’s original film version of The Wolfman. 

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Of all the great Universal movie monsters, my favorite is found in the 1941 film The Wolfman. Lon Chaney’s portrayal of Larry Talbot offers more than just a classic horror story about a man who becomes a werewolf. It’s a tale of isolation, fear, and a struggle for survival in the face of an overwhelming and terrifying transformation. In short, it is the most psychological of all the Universal movie monsters. Much like a corporate whistleblower, Talbot finds himself caught in a situation where the truth is a burden, and no one wants to listen. Instead of being understood and supported, he is feared, rejected, and left to fend for himself.

For compliance professionals, The Wolfman provides a vivid metaphor for the journey of whistleblowers. Whistleblowers often find themselves isolated, facing potential retaliation, and struggling to navigate the consequences of their decision to report wrongdoing. In this post, we’ll explore how to create a culture that encourages whistleblowers to come forward, keeps them informed throughout the process, and protects them from retaliation, all through the lens of The Wolfman. We will also assess the 2024 Evaluation of Corporate Compliance Programs (2024 ECCP) and Nicole Argentieri’s commentary on these issues.

Creating a Safe Space: Encouraging Whistleblowers to Come Forward

In The Wolfman, Larry Talbot is plagued by the knowledge of his transformation, but he finds no one willing to help or believe him. He is trapped in his new reality, just as whistleblowers can feel trapped by the knowledge of corporate misconduct. The first step in supporting whistleblowers is creating an environment where they feel safe and encouraged to speak up.

The 2024 ECCP underscores the importance of building a culture where employees feel empowered to raise concerns without fear. It emphasizes the need for companies to proactively encourage internal reporting mechanisms, making it clear that the company values integrity and transparency. Compliance professionals must ensure that reporting channels are available, actively promoted, and trusted.

In her commentary on the 2024 ECCP, Nicole Argentieri highlights that one key element in encouraging whistleblowers is leadership’s tone from the top. Executives and senior management must demonstrate a commitment to ethical behavior, ensuring that whistleblowing is accepted and valued. Whistleblowers need to know that their reports will be taken seriously and their concerns will be addressed.

Talbot’s cries for help go unheard in The Wolfman, leading to disastrous consequences. In the corporate world, businesses must avoid this fate by ensuring whistleblowers are not ignored or dismissed. The 2024 ECCP recommends that companies provide multiple, accessible channels for reporting, including anonymous options so that employees feel comfortable coming forward regardless of their circumstances.

Transparency Throughout the Process: Keeping Whistleblowers Informed

Just as Larry Talbot struggles with the unknown and is left in the dark about his fate, whistleblowers often find themselves cut off after making a report. They may need clarification about what’s happening with their complaint, whether it’s being investigated, and the next steps. This lack of communication can discourage future whistleblowers and lead to feelings of abandonment.

The 2024 ECCP stresses the importance of maintaining open lines of communication with whistleblowers throughout the investigation process. Once a report has been made, it is critical to keep whistleblowers informed about the status of their complaint. This does not mean sharing sensitive investigation details but providing regular updates so that the whistleblower knows their concerns are being taken seriously.

Argentieri has echoed this sentiment, noting that one of the most common frustrations whistleblowers face is a lack of transparency after they come forward. She argues that compliance teams must ensure whistleblowers are not wondering what will happen next. A well-managed whistleblower program includes clear communication protocols that keep whistleblowers engaged and reassured.

In The Wolfman, Talbot’s inability to find answers drives him to despair. Businesses must avoid this by ensuring whistleblowers feel supported and heard throughout the process. Compliance officers should regularly touch base with whistleblowers, letting them know that their concerns are being addressed, that their identity is being protected and that appropriate actions are being taken.

Protection from Retaliation: Safeguarding Whistleblowers

One of the central themes in The Wolfman is Larry Talbot’s fear of being hunted and rejected. Similarly, whistleblowers often fear retaliation, whether in the form of termination, demotion, or ostracization. Protecting whistleblowers from retaliation is a legal obligation and a moral imperative that helps foster a culture of compliance and trust.

The 2024 ECCP strongly emphasizes retaliation protections. It advises that companies must have robust policies to prevent retaliation and provide clear avenues for whistleblowers to report any retaliatory behavior. This means more than just having a policy on paper—compliance teams must actively enforce these protections and monitor for any signs of retaliation.

Nicole Argentieri has weighed in on this issue, noting that while many companies claim anti-retaliation policies, enforcement can be lacking. She emphasizes the need for companies to create a system of checks and balances to ensure that retaliation does not occur, particularly in the form of subtle, indirect actions that might otherwise go unnoticed. Retaliation doesn’t always come as a formal firing—it can be a change in duties, exclusion from meetings, or a negative shift in workplace relationships.

In The Wolfman, Talbot becomes a hunted figure, chased down by those who fear and misunderstand him. In the corporate world, whistleblowers must never feel like they are being hunted or targeted for their decision to report misconduct. The ECCP advises companies to protect whistleblowers and offer additional support services, such as counseling, if needed, to help them navigate the emotional strain of coming forward.

Building a Culture of Trust and Integrity

The most important lesson from The Wolfman is the need for trust. Larry Talbot finds himself abandoned and isolated because the people around him refuse to trust his warnings. A strong compliance program must avoid this trap by building a culture of trust and integrity. Employees need to believe that they will be treated fairly, protected, and supported if they come forward with a report.

The 2024 ECCP highlights that trust is the foundation of a successful compliance program. Companies must work to build an environment where whistleblowers are seen as vital contributors to the company’s ethical health. This includes recognizing the courage it takes to come forward and offering praise or acknowledgment for whistleblowers who help protect the company from greater risks.

Argentieri has noted that companies should integrate their whistleblower programs into the broader corporate culture, making whistleblowing a routine and accepted part of the business rather than an extraordinary act of bravery. This normalization of whistleblowing helps to remove the stigma and encourages more employees to speak up when they see something wrong.

Creating a Supportive Whistleblower Program

The Wolfman offers us a powerful analogy for the journey of whistleblowers within a company. Like Larry Talbot, whistleblowers often face fear, isolation, and a lack of support. However, the lessons from The Wolfman, coupled with the guidance from the 2024 ECCP and Nicole Argentieri’s commentary, provide a roadmap for how companies can create a more supportive environment for whistleblowers.

Encouraging whistleblowers starts with creating a culture where employees feel safe and empowered to report misconduct. Keeping them informed throughout the process is essential for maintaining their trust and confidence. Finally, protecting whistleblowers from retaliation ensures that they—and others—continue to feel comfortable raising concerns.

By building a robust and transparent whistleblower program, compliance professionals can help their organizations navigate the complexities of corporate risk, protect their employees, and safeguard the company’s reputation. In doing so, they avoid the tragic fate of The Wolfman and create an environment where the truth is not a burden but a pathway to a stronger, more ethical company.

Join us tomorrow for our final consideration of compliance through the classic Universal Movie Monsters lens as we consider corporate culture and Boris Karloff’s version of The Mummy.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 39 – The TD Bank 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!

In this episode, co-hosts Kristy Grant-Hart and Tom Fox tackle several high-profile compliance issues. They start with TD Bank’s $3 billion money laundering scandal, exploring how inadequate compliance measures and lack of investment enabled a decade-long operation involving $18.3 trillion in questionable transactions. The discussion critiques the penalties imposed on TD Bank and reflects on the broader industry implications. The hosts then shift focus to collateral damage from fentanyl, human trafficking, modern slavery, and terrorist financing, spotlighting the OCC’s novel restrictive actions and an SEC enforcement case involving Indian bribery schemes by Moog.

Transitioning to corporate compliance dynamics, the podcast covers the Texas incident involving Deloitte’s mishandling of a convicted felon’s loan application, raising significant questions about due diligence. Frances Haugen’s advocacy for stronger whistleblower protections, particularly in the AI sector, gets highlighted. The episode concludes by addressing the legal ramifications of anti-boycott provisions, the complexities of election season in the workplace, and recent developments in the Boeing case, encapsulating these serious discussions with a humorous note on a bizarre Florida man incident.

Stories Include:

  • TD Bank Money Laundering Scandal
  • Caremark Claims and Broader Implications
  • Indian Bribery Case and SEC Enforcement
  • Debating the ECCP Guidance
  • Texas’ $5 Billion Power Plant Scandal
  • Facebook Whistleblower Frances Haugen Speaks Out
  • Understanding Anti-Boycott Provisions
  • Managing Politics in the Workplace
  • Boeing’s Legal Troubles and DEI Concerns
  • Florida Man’s Unusual Drug Complaint

 Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

Prove Your Worth

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Compliance Tip of the Day

Compliance Tip of the Day: DOJ Whistleblower Financial Incentive Program

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.

Today, we consider the remarks by Principal Deputy Assistant Attorney General Nicole M. Argentieri on the DOJ Corporate Whistleblower Incentive Program and her review of its early results.

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Compliance Tip of the Day

Compliance Tip of the Day: Fostering a Culture of Speak Up

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.

Today, we explore how the DOJ has placed significant emphasis on encouraging a culture where employees feel comfortable reporting misconduct.