FCPA Compliance Report

Thomas Fox
  • 4.7 (21)
  • Business
  • Updated Biweekly

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. 6d ago

    Charisma Doesn’t Scale, Controls Do: Compliance Lessons from Ted Lasso

    In this episode, I take things in a very different direction. Last week I did a 5-part blog post series on leadership lessons from the hit TV show Ted Lasso. I took those 5 blog posts and fed them into Notebook LM. What came out, in the AI voices of Timothy and Fiona, is what I posted for this podcast. Timothy and Fiona use Ted Lasso characters as operational profiles to show why empathetic leadership and “good vibes” are insufficient under compliance frameworks like the DOJ ECCP, COSO, and the Caremark Doctrine. Some of the analysis includes: Ted Lasso creates psychological safety but introduces key-person risk by relying on an open-door culture without institutional “listen-up” systems, case logging, escalation, and anti-retaliation protections; his immediate forgiveness of Rebecca’s sabotage illustrates why mercy cannot replace investigation, evidence preservation, root-cause analysis, and remediation. Rebecca Welton exemplifies corrupted tone at the top and conflicts of interest, including her relationship with Sam, before shifting toward accountable governance by rejecting unethical commercial moves and selling 49% to fans. Keeley Jones highlights governance debt from rapid scaling, affinity hiring, and investor conflicts, leading to incident-response and third-party concentration failures. Roy Kent demonstrates “tone in the middle,” accountability, and root-cause diagnosis, but also risks of unchecked informal authority. Nate Shelley shows the danger of promoting technical skill without evaluating leadership ethics, enabling “relocating harm,” data silos, and a major confidentiality leak—reinforcing that auditable controls, oversight, and monitoring must outlast charisma. I would really like to hear your thoughts on this podcast and the approach I have taken. I would greatly appreciate it if you left a comment or emailed me your reaction to both my use of Notebook LM for this analysis and the AI-generated voices for Timothy and Fiona. Blog Posts on the following Ted Lasso characters: Ted Lasso Rebecca Welton Nate Shelley Roy Kent Keeley Jones Other Takes on Ted Lasso Tom and Matt Kelly on Ted Lasso in Compliance into the Weeds Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

    Charisma Doesn’t Scale, Controls Do: Compliance Lessons from Ted Lasso

  2. Aug 17

    Data Analytics in Compliance: Lessons from Scoular

    In this episode, Tom Fox welcomes back Vince Walden, CEO of konaAI, which is the sponsor of this podcast series. Vince is well known for his leadership in data analytics, machine learning, and AI, and we take a deep dive into all of these topics through the lens of the Scoular FCPA Enforcement action. The Scoular case is a unique learning tool for using data analytics, machine learning, and AI for compliance. In this matter, roughly 2,000 near-$2,000 payments were tied to customs brokerage activity. This case illustrates broader uses of data analytics beyond numbers, including mining unstructured text in invoice and payment-description fields (e.g., repeated terms like “re-inspection fee” and Spanish phrases) and linking it to structured AP data. Walden explains how combining structured and unstructured data reduces investigator bias, how round-dollar and repetitive payments to high-risk vendors can be continuously risk scored using hundreds of tests, and how machine learning can “find more like this” across large transaction populations. We discuss integrating communications data when available, using monitoring within typical 30–60-day payment cycles to prevent payments, supporting self-disclosure decisions amid DOJ guidance, and launching a minimum viable analytics program by starting with AP spend, invoices, POs, and payments pulled from ERP systems. Key highlights: Structured vs. Unstructured Data Red Flags Round Dollars Text Mining and Three Lines Transactional Fingerprints Machine Learning for Compliance Linking Comms and Payments Prevention Through Monitoring Continuous Improvement and ROI Self-Disclosure and Culture Data 90-Day Analytics Roadmap Resources: konaAI Vince Walden 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

    Data Analytics in Compliance: Lessons from Scoular

  3. Aug 10

    The Berko Verdict with Mike Volkov

    In this episode, Tom Fox welcomes back his good friend and colleague Mike Volkov and takes a deep dive into the Asante Berko FCPA guilty verdict. They question why Berko went to trial given the strength of the case, discuss the power of recorded statements like requests to use private email, and highlight Goldman Sachs compliance personnel as corroborating witnesses after the firm stopped the transaction and disclosed it. They conclude with compliance lessons that include rigorous deal due diligence, escalation of red flags, sampling internal communications, and monitoring attempts to move discussions off-channel. Key highlights: Quick Jury Verdict Recordings And Emails Goldman Compliance Witness Sentencing Trial Penalty SEC Settlement Strategy Compliance Lessons Red Flags Resources Berko Trial Blog Post series on FCPA Compliance and Ethics Report Mike Volkov 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

    The Berko Verdict with Mike Volkov

  4. Aug 3

    Matt Ellis Wrap-Up from Cartels, FTO Risk, and Corporate Compliance Conference

    In this episode, Tom Fox welcomes back Matt Ellis of Miller & Chevalier to recap ACI’s inaugural two-day Cartel Conference in Washington, DC, highlighting an unusually collaborative, high-energy atmosphere around emerging cartel/TCO/FTO compliance risks in Latin America. They discuss DOJ’s Scoular FCPA action as illustrating the long tail of enforcement and a high bar for managing cartel-related and national security risks, while noting the DPA’s remedial steps focus more on traditional anti-corruption controls than TCO/FTO-specific guidance. Government participants emphasized a “whole of government” approach, voluntary disclosure, and potential public-private engagement (including embassy attachés and Treasury) in high-risk scenarios. Key themes included narrow duress defenses, complex “imposter” risks, evolving due diligence beyond traditional screening using data/anomaly detection and local intelligence, and the need to integrate compliance across AML, sanctions, security, and supply chain given severe reputational and business consequences of terrorist or cartel support. Key highlights: Conference Vibe and Energy Scoular FCPA Case Takeaways When to Engage Government Duress Defense and Safety Payments Cartel-Focused Due Diligence AML Lessons for Banks Breaking Silos in Compliance Parallels to Early FCPA Era National Security Stakes Resources: ACI National FCPA and Global Anti-Corruption Conference, December 10-11 at the Gaylord National Resort & Convention Center, Washington, DC 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 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

    Matt Ellis Wrap-Up from Cartels, FTO Risk, and Corporate Compliance Conference

  5. Jul 27

    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

  6. Jul 20

    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

  7. 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”

  8. Jun 29

    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
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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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