FCPA Compliance Report

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes back James Tillen and Ann Sultan, both partners at Miller & Chevalier, and takes a deep dive into four recent DOJ policy announcements: FCPA Enforcement, White-Collar Enforcement, Criminal Enforcement Policy, and the Whistleblower Pilot Program.

They take a deep dive into Deputy Attorney General Todd Blanche’s memo on Investigations and Enforcement of the FCPA, reviewing the stated main goals of the DOJ and how prosecutors are supposed to achieve these goals. They also consider three directives to prosecutors: focus on cases involving individual misconduct, proceed expeditiously, and consider the collateral consequences. They also examine the White Collar Plan and CEP and ask if we have shifted from a presumption of declination to a more tangible framework and conclude by reviewing what compliance professionals need to consider and investigate now.

Key highlights include:

• How does the principle of “not attribute[ing] nonspecific malfeasance to corporate structures” impact potential prosecutions of companies and individuals?
• And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations?
• What does it mean for companies that the DOJ is prioritizing “serious misconduct”?
• What are the implications of the DOJ’s stated intent to avoid penalizing “routine business practices in other nations”?
• Do you see this as a shift in focus for the DOJ to non-US companies?
• Other DOJ Priorities & Announcements
• Policy Shifts and Clarifications
• Looking Ahead: What’s on the Horizon

Resources:

FCPA Spring Review 2025 – Miller & Chevalier

DOJ Criminal Division White Collar Plan

Guidelines for Investigations and Enforcement of the FCPA

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For more information on the use of AI in compliance programs, see Tom Fox’s new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

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Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration.

At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals.

In this episode, Tom Fox talks with Chris Mason, who recently launched his risk advisory practice, Woodhorn Global, focusing on due diligence investigations. Chris shares insights about his upcoming presentations at the #RiskGRC conference in July, focusing on AI investments and the impact of political uncertainty on the GRC (Governance, Risk, and Compliance) community. They discuss the significance of AI in the field and the importance of adapting to political changes. Chris also emphasizes the value of in-person events in understanding best practices and navigating the evolving risk landscape.

 Resources:

#Risk Conference Series

#RiskNYC—Tickets and Information

Chris Mason on LinkedIn

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Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration.

At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy, and combating misinformation. All while meeting with the country’s top #Risk management professionals.

In this episode, Tom Fox talks with Gwen Hassan, the Chief Compliance Officer for Unisys Corporation, about her role and the upcoming #RiskNYC conference. Gwen shares insights into Unisys’ operations, including the various technologies and services they provide, and highlights her responsibilities in managing global ethics, compliance, and trade compliance risks. She also gives a teaser about her panel presentation on the compliance and ethics risks associated with artificial intelligence, stressing the importance of understanding AI’s impact on company culture and regulatory compliance. Gwen expresses her excitement about the conference, emphasizing the value of engaging with fellow risk management experts.

Resources:

#Risk Conference Series

#RiskNYC—Tickets and Information

Gwen Hassan on LinkedIn

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Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration.

At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals.

In this episode, Tom Fox welcomes Michael Rasmussen, a renowned expert in Governance, Risk Management, and Compliance (GRC), often referred to as the ‘father of GRC.’ Michael shares insights into his contributions to the field, including his work with the SEG GRC Capability Model. The conversation highlights Michael’s anticipated presentation on ‘The Future of GRC’ at the upcoming risk conference in New York City. Drawing inspiration from Star Trek (TOS, and how can you not love that?), Michael emphasizes the importance of managing business risks effectively. The discussion also touches on the benefits of face-to-face interactions and networking opportunities at such conferences.

Resources:

#Risk Conference Series

#RiskNYC—Tickets and Information

Michael Rasmussen on LinkedIn

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Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration.

At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy, and combating misinformation. All while meeting with the country’s top #Risk management professionals.

In this episode, Tom Fox talks with Matt Kelly about his presentation on the importance of understanding how AI can be productively adopted within enterprises, as well as the ethical challenges it presents, including discrimination and data validity. Matt also discusses the importance of AI governance and offers a preview of his upcoming presentation on this topic. Matt expresses his eagerness to engage with other GRC professionals at the forthcoming conference to exchange ideas and discuss emerging risks in third-party and vendor risk management.

Resources:

#Risk Conference Series

#RiskNYC—Tickets and Information

Matt Kelly on LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes back Ariel D. Weindling, founder of NotMe Solutions, a whistleblower reporting solution, to discuss innovations and strategies for enhancing speak-up cultures in organizations.

Weindling, with a background in employment law, critiques current whistleblower systems for prioritizing regulatory compliance over genuine employee engagement. He shares insights on implementing effective speak-up programs, emphasizing the importance of trust, timely resolution, and a culture of listening. Weindling also highlights key findings from over 20,000 reports through NotMe Solutions, including common issues reported and the importance of leadership in fostering a culture of speaking up.

Key highlights:

• Challenges in Current Speak Up Cultures
• Building Effective Compliance Programs
• Evaluating Existing Speak Up Systems
• The Importance of Listening in Speak Up Cultures
• Role of Leadership in Speak Up Culture
• Innovations in the Speak Up Space

Resources:

Ariel D. Weindling on LinkedIn

Not Me (Company)

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For more information on the use of AI in Compliance programs, see my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. Today, Tom Fox cross-posts an episode from the BCG Podcast. In it, host Hanjo Siebert visits with konaAI CEO Vince Walden. They discuss the critical role of data and culture in achieving effective compliance, exploring the importance of interdepartmental collaboration, the evolving compliance landscape, and real-world examples of fraud detection. Walden emphasizes that while strategy is important, a strong organizational culture is essential for successful execution. He explains how data serves as a transparency agent and outlines the need for a collective approach to managing fraud risk. Listen in to gain insights into the challenges and best practices in modern compliance.

Key highlights:

• The Importance of Transaction Monitoring
• Challenges in Fraud Risk Management
• Collaborative Approaches to Compliance
• konaAI Role in Modern Compliance
• Real-World Fraud Cases and Lessons Learned
• The Impact of Business Culture on Fraud Prevention
• Fostering a Culture of Transparency

Resources:

Vince Walden on LinkedIn

konaAI

Original Podcast Recording

Tom Fox

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For more information on the use of AI in Compliance programs, see my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com.

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. Today, Tom Fox visited with Sarah Cole, a former solicitor turned founder of Integrity First Coaching and Cole Forums.

Sarah shares her journey from litigation to running legal events and eventually founding her peer support organization for senior executives. She discusses the isolation leaders feel, the importance of embedding values into corporate behavior, and the critical need for purpose-driven leadership. Sarah emphasizes the complexities faced by modern leaders, including decision fatigue and the importance of self-care. She also discusses the benefits of safe, confidential peer support environments, which can provide truthful feedback and help leaders navigate ethical and emotional challenges.

Key highlights:

• Sarah Cole’s Professional Journey
• Founding Integrity First Coaching and Coal Forums
• The Power of Peer Support for Leaders
• Challenges and Complexities of Modern Leadership
• Purpose-Driven Leadership

Resources

Sarah Cole on LinkedIn

coleforums.com (Company)

integrityfirstcoaching.com (Company)

coleforums.com/leaderspodcast (Podcast)

Tom Fox

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For more information on the use of AI in Compliance programs, see Tom Fox’s new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. This podcast comes from a webinar hosted by KonaAI on Tom Fox’s latest book, Ûpping Your Game. On this webinar, Tom is joined by Vince Walden, CEO of konaAI; Hemma Lomax, Deputy General Counsel, Vice President, Global Head of Ethics and Compliance at Docusign; and Carl Hahn and Matt Galvin, both from Gentic Global Advisors PLLC.

The discussion revolves around compliance, with thought leaders delving into how organizations can enhance their performance by utilizing emerging technologies and compliance strategies. The conversation begins with a focus on the transformative role of AI in compliance, highlighting its ability to support continuous monitoring, predictive analytics, and embedding compliance into day-to-day business operations. The panel emphasizes the rise of “compliance as a service” and the growing need to prioritize user experience, particularly in third-party risk management and digital transformations. The panel addresses key challenges, such as overcoming resistance from business process owners, and emphasizes the importance of using data strategically to drive better compliance outcomes. The panel introduces the concept of the “Office of Unlock” as a collaborative model to break down silos and promote agility. They also discuss change management, AI governance, and tailoring compliance communications to specific audiences. The episode concludes with practical advice for compliance officers and a forward-looking discussion on aligning compliance programs with evolving organizational and regulatory landscapes.

Key highlights:

• Upping Your Game
• Embedded Compliance
• What’s the business value?
• What steps should you take right now

Resources

Hemma Lomax on LinkedIn

Vince Walden on LinkedIn

Matt Galvin on LinkedIn

Carl Hahn on LinkedIn

KonaAI

Gentic Global Advisors

Tom Fox

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For more information on the use of AI in compliance programs, see Tom Fox’s new book, Upping Your Game. You can purchase a copy of the book on Amazon.com.

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. Tom Fox is joined by Lisa Fine, Ellen Hunt, and Hemma Lomax from the Great Women in Compliance podcast for our annual GWIC/FCPA Compliance Report cross-post podcast. We recorded this at Compliance Week 2025.

In this year of uncertainty and change in compliance, we discussed the need to revisit and emphasize foundational ethics amid the evolving compliance landscape, seeing uncertainty as a chance for professional growth and deeper ethical reflection. We also discussed integrating ethics into compliance functions and advocating for a community-oriented approach that respects diverse viewpoints and fosters global perspectives; highlighted the importance of innovative strategies and understanding human behavior, advocating for creative approaches like podcasts to foster a speak-up culture and stressing the use of technology and coaching to enhance ethical decision-making, ultimately contributing to a robust corporate culture capable of navigating international compliance challenges.

Key highlights:

• Ethical Decision-Making in Times of Change and in a Global Business Arena
• Global Training Program for Anti-Corruption Enforcement
• Promoting Ethical Culture and Fair Treatment
• Harnessing Collective Energy for Compliance Excellence

Resources:

Lisa Fine on LinkedIn

Ellen Hunt on LinkedIn

Hemma Lomax on LinkedIn

Tom Fox

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For more information on the use of AI in Compliance programs, see my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

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