FCPA Compliance Report

Thomas Fox

The FCPA Compliance Report is the longest running podcast in the in compliance and business ethics. Join its award-winning host, Tom Fox, the Voice of Compliance as he visits with top compliance practitioners, key figures from business, the government and law firms in the top podcast dedicated to all things compliance.

  1. 2 days ago

    The Business Case for Going Back into Venezuela with Loren Steffy

    Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back former Houston Chronicle business columnist Loren Steffy to discuss the business aspects of returning to Venezuela. Loren Steffy has spent much of his career analyzing the energy industry and the challenges of oil and gas development. On Venezuela, he argues that Trump administration moves are unlikely to produce meaningful gains in oil output and are more likely to deepen market uncertainty, especially in West Texas. Steffy says Venezuela’s oil sector is effectively too risky and too unstable for major foreign investment because its infrastructure has deteriorated, its legal and political environment remains unclear, and rebuilding production would require major capital, advanced technology, and years of work. Even if some companies were willing to take a chance, he believes the combination of insecurity, weak rules, and Trump-era policy uncertainty makes a broad investment revival in Venezuela highly unlikely. Resources: Loren Steffy on LinkedIn Stoney Creek Publishing Tom Fox Instagram Facebook YouTube Twitter LinkedIn The FCPA Compliance Report was recently named the world’s Best Business Ethics Podcast by FeedSpot. Learn more about your ad choices. Visit megaphone.fm/adchoices

    The Business Case for Going Back into Venezuela with Loren Steffy

  2. 20 Jul

    The Scoular FCPA Enforcement Action: Customs Bribes, Cartel Links, and New Compliance Expectations

    Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Matt Ellis to discuss a newly announced FCPA enforcement action involving Scoular Company. The case invoiced about $400,000 in payments labeled as “reinspection fees” to Mexican customs and food inspectors to move agricultural goods across the Mexico–U.S. border. border, allegedly generating over $6.5 million in avoided costs and raising concerns about cartel-linked beneficiaries. They discuss why customs and customs brokers are recurring high-risk areas in Mexico, how long-running employee involvement suggests broader controls and tone-from-the-top failures, and why these payments are not facilitation payments under Mexican law and given discretionary official acts. Ellis emphasizes analytics on customs documents and broker invoices, stronger third-party diligence beyond traditional screening to address cartel/TCO risks, and defensible governance for WhatsApp/off-channel communications. Despite no voluntary self-disclosure, the company received cooperation credit and a 25% fine reduction, and Ellis previews an ACI conference focused on cartels, TCOs, and compliance in Latin America. Key highlights: Border Bribes and Safety Risks Controls Failures and Monitoring Data Analytics Red Flags Facilitation Payment Myth DOJ Cartel Warning and Implications Rethinking Due Diligence for Cartels WhatsApp and Messaging Governance Cooperation, Credit, and Remediation Resources: Cartels, TCOs and Compliance in Latin America, July 20-21 Matt Ellis on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn The FCPA Compliance Report was recently named the world’s best business ethics podcast by FeedSpot. Learn more about your ad choices. Visit megaphone.fm/adchoices

    The Scoular FCPA Enforcement Action: Customs Bribes, Cartel Links, and New Compliance Expectations

  3. Episode 815 Trailer

    AI in Compliance and Eastward AI’s Continuous Risk “Reality Check”

    Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Gerry Zack, and they discuss the growing use of AI in compliance and the launch of Eastward AI. Zack says many organizations are uncertain and paralyzed, while others range from using ChatGPT at a basic level to building or buying specialized tools rather than seeking a “big machine.” AI is now embedded across compliance functions, from hotline chatbots and policy/control mapping to monitoring, investigations (which Zack cautions against over-automating), and behavioral analytics. Eastward AI began as a CSRD double-materiality assessment tool but expanded to encompass broader enterprise and compliance risk management, aligned with frameworks including COSO ERM, DOJ expectations, ISO 37301, and ISO 31000. Zack describes development with a skilled programming team, beta “design partners,” and a “Reality Check” feature that rapidly scans global information to update risk assessments and support scenario modeling continuously. This combination has drawn interest from CCOs, CROs, GCs, and strategy leaders. Eastward.ai is now publicly available. Key highlights: AI in Compliance Today Eastward AI Origin Story MVP and Design Partners Reality Check Feature Scenario Modeling and Strategy Expanding Compliance Remit Resources: Gerry Zack on LinkedIn RiskTrek Eastward AI Tom Fox Instagram Facebook YouTube Twitter LinkedIn The FCPA Compliance Report was recently named the world’s Best Business Ethics Podcast by FeedSpot. Learn more about your ad choices. Visit megaphone.fm/adchoices

    AI in Compliance and Eastward AI’s Continuous Risk “Reality Check”

  4. 29 Jun

    Managing Compliance and National Security Risks When Doing Business in the DRC, Part 2

    In this episode, Tom Fox welcomes David Simon, Partner at Foley & Lardner; Jack Korba, Of Counsel at Foley & Lardner; and Olivier Bustin, a Partner at Pinsent Masons, to discuss doing business in and with the Democratic Republic of the Congo (DRC). This is the second part of a two-part series on this topic, in which they present a detailed approach to evaluating and managing travel to a high-risk country or region. They discuss how companies investing in high-risk jurisdictions like the Democratic Republic of the Congo should treat diligence as ongoing risk management, using tailored controls, audits, and continuous monitoring informed by geopolitical developments and government/regulatory priorities (including signals such as announcements and sector focus, such as critical minerals). The speakers emphasize pragmatism: accepting some ambiguity while designing jurisdiction-specific compliance frameworks, rather than placing standard programs on “autopilot” and maintaining active C-suite and board engagement. They stress building and documenting a rational, risk-tolerant decision process that can be explained to regulators (e.g., DOJ/SEC), including knowing counterparties and local dynamics, implementing real controls, and escalating decisions appropriately. Key pitfalls to avoid include overcommitting to projects beyond risk tolerance and entering transactions without sufficient preparation. The panel also urges compliance leaders not to be paralyzed by fear, to shape opportunities early, and to note market opportunities and signals of U.S. engagement, such as financing for the Lobito railway corridor. Key highlights: Ongoing Risk Controls Pragmatism In High Risk Regulator Ready Diligence Mistakes To Avoid Where To Start Resources: David Simon Jack Korba Olivier Bustin Foley & Lardner Pinsent Masons The Democratic Republic of the Congo as a Near-Term Strategic Opportunity for U.S. Companies Part 1 Part 2 Part 3 Tom Fox Instagram Facebook YouTube Twitter LinkedIn To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out my latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Managing Compliance and National Security Risks When Doing Business in the DRC, Part 2

  5. 22 Jun

    Managing Compliance and National Security Risks When Doing Business in the DRC, Part 1

    In this episode, Tom Fox welcomes David Simon, Partner at Foley & Lardner; Jack Korba, Of Counsel at Foley & Lardner; and Olivier Bustin, a Partner at Pinsent Masons, to talk about doing business in and with the Democratic Republic of the Congo (DRC). This is the first part of a two-part series on this topic. The guests present a detailed approach to evaluating and managing travel into a high-risk country or region. The three argue that while governance and logistics risks remain, improved infrastructure and heightened strategic importance of the DRC’s critical minerals (including cobalt, coltan, lithium, manganese, and rare earths) make risks more manageable and the market more relevant, with noted U.S. government continuity across administrations. They discuss opportunities beyond mining, including power, logistics, banking/insurance, tech, entertainment, and education, while emphasizing infrastructure and bankability constraints. Korba outlines national security, sanctions/export controls, and supply chain “adjacency” risks, as well as the need for sector-specific analysis. The panel highlights “choke points” stemming from concentrated power and weak institutions, and Bustin explains why local content/ownership rules and patronage dynamics require diligence that goes beyond nominal ownership. They conclude by applying a risk-based compliance approach, devoting enhanced resources to higher-risk projects and counterparties. Key highlights: Why DRC Now Beyond Mining Opportunities National Security Risks Choke Points Explained Local Ownership Diligence Risk-Based Compliance Resources: David Simon Jack Korba Olivier Bustin Foley & Lardner Pinsent Masons The Democratic Republic of the Congo as a Near-Term Strategic Opportunity for U.S. Companies Part 1 Part 2 Part 3 Tom Fox Instagram Facebook YouTube Twitter LinkedIn To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out my latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Managing Compliance and National Security Risks When Doing Business in the DRC, Part 1

  6. 15 Jun

    Data Defensibility: The Foundation of AI Readiness with George Tziahanas

    In this episode, Tom Fox welcomes George Tziahanas, VP of Compliance and Associate General Counsel at Archive360, who brings a practical legal and governance perspective to the challenges of AI and data governance. George argues that organizations must go beyond simply storing data and instead prove their integrity, lineage, provenance, and accountability so the data is defensible for compliance and AI use. He also believes AI governance should follow the model of mature security programs, with clear ownership, governing councils, and risk frameworks that make responsibility visible to regulators. For him, the path to compliant, defensible data starts with strong inventories, governed environments, and risk-tiered oversight that protects sensitive uses while still enabling innovation. Key highlights: Walking Upstream: Defending AI Data and Systems Who Is Ultimately Responsible for AI Governance Zubulake rulings reshape e-discovery compliance playbook Dark Data Risks in DOJ Compliance Programs Mapping data inventory back into legacy systems Simple risk tiering for AI compliance oversight Resources: Archive360 George Tziahanas on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

  7. 8 Jun

    Leading with Invitation: Communications, Leadership, and Compliance with Dr. Dennis Cummins

    In this episode, Tom Fox welcomes Dr. Dennis Cummins to discuss his latest book, Invitational Selling: The Human Connection Advantage. Dr. Cummins is a renowned expert in the field of invitational selling, with extensive experience presenting and selling from the stage globally. He discovered that prioritizing conversations and genuine connections over high-pressure sales tactics not only aligned with his values but also enhanced his effectiveness in sales. This led him to develop the concept of invitational selling, which emphasizes sharing one’s gifts and talents to empower others and help them benefit from available services. Dr. Cummins encapsulated his philosophy in his new book, leveraging his global speaking engagements and interactions with various companies. In his book Dr. Cummins emphasizes the importance of building authentic connections in sales rather than relying on high-pressure tactics. He introduces the concept of ‘Invitational Selling,’ which involves connecting with customers, conveying the benefits, and inviting them to engage, thereby fostering genuine relationships and enhancing sales effectiveness. This approach is applicable not only in sales but also in leadership and family dynamics, promoting engagement and collaboration through invitation rather than coercion. As customers are inundated with sales messages and wary due to information overload, prioritizing empathy and understanding separates successful sales professionals in a technology-driven world. Real-life examples, such as Lauren’s bead bracelets, highlight that product value extends beyond materials to the emotional connections and meanings they hold for customers. Committed to giving back, he has pledged all proceeds from the book’s initial launch to the Make-A-Wish Foundation. Key highlights: Authentic connections in sales enhance effectiveness and drive sales growth. Invitational selling focuses on connecting, conveying, and converting to inspire buy-in from employees and foster collaboration. Maintaining a personal touch and understanding customer needs sets sales professionals apart in a technology-driven world. Balancing AI efficiency with personal elements is crucial to overcoming trust issues and fostering genuine connections. The true value of a product lies in the emotions, connections, and meanings it represents to individuals. Resources: Invitational Selling: The Human Connection Advantage Dr. Dennis Cummins on LinkedIn  Tom Fox Instagram Facebook YouTube Twitter LinkedIn To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Leading with Invitation: Communications, Leadership, and Compliance with Dr. Dennis Cummins

  8. 1 Jun

    Matt Ellis on Cartels, FTO Risk, and Corporate Compliance in Latin America

    In this episode, Tom Fox welcomes Matt Ellis of Miller & Chevalier about the ACI “Cartels, TCOs and Compliance in Latin America” forum (July 20–21, Washington, DC) and why cartel/TCO/FTO risk is a timely 2026 compliance priority. Ellis describes the Trump administration’s focus on cartels, fentanyl, China’s influence, and the expanded enforcement toolkit—FCPA guidance linking to cartel activity, sanctions, AML actions (including FinCEN orders against Mexican financial institutions), and cartel FTO designations implicating the Anti-Terrorism Act. They discuss how cartels infiltrate supply chains, creating “material support” exposure, and why due diligence must go beyond traditional screening to on-the-ground intelligence and nuanced red flags. Ellis notes government interest in compliance expectations, extortion-payment considerations, the Lafarge/ISIS example, anticipated investigations, broader regional risk (Mexico, Venezuela, Colombia, Brazil), and increased multi-agency coordination and potential dialogue with U.S. authorities. Key highlights: Why This Conference Now Due Diligence Goes Deeper Extortion and Self-Reporting Beyond Mexico Regional Risks Whole-of-Government Focus When to Engage Government Resources: Cartels, TCOs and Compliance in Latin America, July 20-21 Matt Ellis on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Matt Ellis on Cartels, FTO Risk, and Corporate Compliance in Latin America
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About

The FCPA Compliance Report is the longest running podcast in the in compliance and business ethics. Join its award-winning host, Tom Fox, the Voice of Compliance as he visits with top compliance practitioners, key figures from business, the government and law firms in the top podcast dedicated to all things compliance.

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  • Creator
    Thomas Fox
  • Years Active
    2013 - 2026
  • Episodes
    1.6k
  • Rating
    Clean

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