Fcpa Compliance Report

In this episode, Tom Fox welcomes former Wall Street trader Joseph De Gregorio, who was federally convicted and now applies a “compliance rebuild” methodology to demonstrate genuine remediation under legal scrutiny. This is Part 1 of a two-part podcast series. Using the Matthew Bowyer illegal sports betting case, Joseph explains the federal pre-sentence interview and pre-sentence report (PSR) process, emphasizing that the probation officer’s credibility assessment and PSR narrative heavily influence sentencing and downstream treatment across the federal system. He describes submitting a 3,500-word personal narrative before the PSR interview, which was attached in full and cited by the judge as mitigation, resulting in a one-year-and-a-day sentence rather than the government’s four-year request. Joseph maps DOJ’s seven corporate compliance program dimensions to individuals via a personal compliance manual, independent accountability structure, credentialed education, verifiable monitoring, documented transpar

In this episode, Tom Fox welcomes Jessica Tillipman, Associate Dean for Government Procurement Law Studies; Government Contracts Advisory Council Distinguished Professorial Lecturer in Government Contracts Law, Practice & Policy. We take a deep dive into federal procurement and compliance. We begin with Tillipman’s recent article “Buying Blind: Corruption Risk and the Erosion of Oversight in Federal AI Procurement.” Tillipman explains how her initial focus on AI as a tool to reduce procurement risk shifted after finding instances of AI exploitation and U.S. regulatory changes, raising concerns that contracting practices (commercial terms, limited audit rights, reduced testing and documentation) worsen AI’s inherent opacity. She contrasts government contracting’s “superpower” rights with transparency and competition mandates tied to taxpayer funds and discusses procurement tradeoffs between speed and oversight. Tillipman distinguishes fraud from waste and abuse, warning against conflating categories. She anal

In this episode, Tom Fox welcomes back Erica Salmon Byrne to talk about Ethisphere’s 20th edition of the World’s Most Ethical Companies. Erica began by noting that there are 19 first-time honorees across 40 industries and 17 countries in the  2026 World’s Most Ethical Companies awards. They discuss the rigorous 250+ question Ethics Quotient and documentation review. They discuss the Ethics Premium using a five-year lookback (Jan 1, 2021–Dec 31, 2025), which showed 8.2% statistically significant outperformance versus a benchmark, based on index-firm analysis with capped company weighting. Beyond outperformance, the data showed a resiliency pattern during volatility: lower drawdowns, less time at the bottom, and faster recovery, which is correlated with practices that protect intangible assets. They highlight common honoree program elements, including transparency on investigations and discipline, more interactive “espresso shot” training, and manager toolkits and expectations to drive culture. They preview th

In this episode, Tom Fox welcomes back Hughes Hubbard partner Mike DeBernardis to discuss the Southern District of New York’s new corporate enforcement voluntary self-disclosure program for financial crimes and why SDNY leadership, including Jay Clayton, likely issued it: to encourage self-disclosure that saves enforcement resources and supports DOJ’s focus on individual accountability. They compare the policy to the (former) DOJ’s Corporate Enforcement Policy, highlighting notable distinctions such as SDNY’s narrower scope (financial/market integrity offenses) and a revised approach to aggravating factors that excludes common CEP considerations like seriousness, pervasiveness, and senior management involvement, while carving out categories including foreign bribery and sanctions evasion, potentially reducing forum shopping. They also examine a “conditional declination” within two to three weeks, its implications for investigation speed and timeliness, and added pressure from whistleblower programs and compr

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is our 800th edition. In this episode, Tom Fox welcomes back Gerry Zack, who recently attended the SCCE Europe conference in Berlin. They begin by noting the differences from the U.S. national conference, including a stronger European focus on behavioral ethics, culture, and community networking. Zack highlights extensive conference attention to AI, including the shift toward agentic AI, practical compliance uses such as identifying policy gaps, enhancing third-party due diligence, and automating anomaly follow-up, while cautioning about investigative risks if AI-generated interview strategies are scrutinized in court. They discuss AI-driven fraud threats (deepfakes, fake invoices, and improved phishing) and the growing concerns about shadow AI and the improper use of confidential information. Zack also describes a company’s experience pursuing ISO 37301 and 37001 certifications and notes ongoing work and lim

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Morgan Lewis partners Carl Valenstein (international corporate law, Latin America) and Katelyn Hilferty (international trade, export controls and sanctions) on whether businesses should consider returning to Venezuela after Maduro’s arrest and President Trump’s announcement. Ed. Note: this podcast was recorded in February, and since then, OFAC has issued New and amended Venezuelan-related General Licenses. The situation remains fluid. Valenstein leads off by noting that he is counselling businesses to engage in “watchful waiting” due to continued instability, corruption, weakened institutions, security risks, uncertainty about elections, and a lack of clear U.S. incentives, such as political risk insurance. Hilferty explains that sanctions relief is narrow: two limited OFAC general licenses focused on Venezuelan-origin oil and U.S.-origin diluents, while most sanctions and broad expor

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, we replay a recent webinar Tom Fox participated in, hosted by EQS. The panel moderator was Steph Holmes, and the panelists were Tom Fox, Mary Shirley, and Matt Kelly. The session focuses on six key 2026 trends for ethics and compliance programs: (1) AI moving from experimentation to operational use, emphasizing deliberate scaling, human-in-the-loop oversight, governance frameworks, monitoring, and managing “shadow AI,” with practical use cases such as policy chatbots, gift/travel/entertainment reviews, and AI-enabled third-party risk lifecycle management; (2) enforcement “volatility” and unpredictable regulatory signals, with emphasis on returning to fundamentals such as documenting program inputs and outcomes, and noting continued activity, including record FCA resolutions and a DOJ whistleblower program award leading to a rapid antitrust settlement; (3) shifting employer–employee dynamics, in

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode,  host Tom Fox welcomes Anik Shah, Director & Senior Legal Counsel at Sandisk, for an insightful discussion about the pivotal changes and enforcement actions around the FCPA in 2025 and their implications for 2026. In 2025, Anik Shah, a preeminent authority on FCPA and anti-corruption enforcement, offers a strategic perspective on the evolving compliance landscape. Given the recent uncertainties following an executive order and the dismissal of high-profile cases, Shah underscores the necessity for companies to maintain robust anti-bribery and anti-corruption controls, especially with potential reprioritization by the Department of Justice. He advocates a proactive risk management approach, emphasizing the importance of third-party risk management and comprehensive training to anticipate and mitigate potential FCPA issues. As enforcement focus shifts toward addressing cartel and transnational crimi

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Marc Duncan, Chief Operating Officer at Salus Solutions, joins Tom to discuss security issues that US companies returning to Venezuela need to address upon reentering the country. They deep dive into understanding and managing security threats across domains such as finance, personnel, corporate structure, and cyber operations. Duncan discusses the importance of viewing problems abstractedly, conducting full-scale threat assessments, and the crucial role of continuous monitoring. He shares insights into working with local communities, ensuring physical and operational security, and developing crisis communication strategies. The conversation also touches on insider threats, technical surveillance countermeasures, and the need for a responsive, flexible security team. Learn how companies, including those operating in high-risk environments such as Venezuela, can effectively prepare for and mitigate

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this inaugural episode of 2026, Tom Fox welcomes back Brent Carlson, a specialist in trade and economic sanctions, focusing on compliance issues related to Venezuela. Tom and Brent discuss the shifting political landscape, potential business opportunities in the energy sector, and the steps compliance professionals need to take to navigate new regulations and restrictions from the export control and trade sanctions perspective. Brent emphasizes the importance of a robust, business-aligned compliance strategy, a non-siloed approach involving all risk disciplines, and proactive dialogue with regulators. They also discuss the heightened enforcement landscape and the need for companies to remain vigilant and adaptable in a rapidly changing global environment. Key highlights: Focus on Venezuela: Navigating Export Controls and Sanctions Business Opportunities and Risks in Venezuela Importance of Understand

Today we have a special edition of the FCPA Compliance and Ethics Report as we begin a preview of speakers and presentations at the upcoming Compliance Week event The Leading Edge: Applying AI and Data Analytics in E&C, which will be held in Fort Lauderdale, January 28 and 29. In this episode, I am joined by Matt Galvin, partner at Steptoe & Johnson, to discuss his presentation with Nicole Diaz, Associate General Counsel, Compliance at OpenAI at the upcoming Compliance Week event, The Leading Edge.     They discuss Galvin's role at Steptoe, his upcoming presentation with Nicole Diaz titled 'Perspectives from Open AI and Steptoe', and the evolving landscape of compliance with AI integration. Galvin shares insights on how AI is reshaping risk management, emphasizing the need for more dynamic and transparent approaches in compliance. The conversation highlights the importance of staying current with rapid technological advancements and regulatory changes.   Key Highlights    ·      Preview of the Leading E

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 2 of a two-part series. This episode delves into the significance of the False Claims Act (FCA) as a critical tool for government enforcement, discussing its constitutionality and potential outcomes before the Supreme Court. The conversation expands to discuss how FCA applies across various areas, such as trade enforcement and tariffs, and how it encourages corporate whistleblowing. Additionally, the discussion highlights the growing role of technology, AI, and ChatGPT in compliance, as well as the risks associated with their use. Other focal points include the importance of conflict-of-interest programs and the impact of ethical conduct on marketplace dynamics. The episode underlines the growing scrutiny from f

Today, we have a special edition of the FCPA Compliance Report, previewing speakers and presentations at the upcoming Compliance Week event, The Leading Edge: Applying AI and Data Analytics in E&C, to be held at The Westin Fort Lauderdale on January 28 and 29. In this episode, Tom Fox is joined by Roxanne Bras Petraeus, CEO of Ethena, and Andrew McBride, Founder & CEO of Integrity Bridge LLC, to discuss their presentation, “Seeing is Believing: Live AI Demos for Ethics and Compliance Leaders.“ Roxanne emphasizes the practical integration of AI within Ethena’s services and its utility for compliance leaders, while Andrew shares insights from his extensive experience in risk and compliance consulting. They highlight their upcoming presentation at The Leading Edge conference, where they will demonstrate 10 AI tools and discuss real-life use cases, opportunities, and limitations of AI in compliance. They also reflect on the evolving role of AI in data analytics and the need for transparency and data validation.

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. We take a short break from our 2-part series with Mike Volkov to review the issues arising from the Trump Administration's invasion of Venezuela. Matt Ellis joins Tom Fox to look at what all this means for companies looking to do business in Venezuela. They discuss the complex landscape of doing business in Venezuela, focusing on the rampant corruption, security challenges, and the implications of U.S. sanctions. They explore the risks associated with engaging with the national oil company, PdVSA, and the broader implications for U.S. companies considering re-entry into the Venezuelan market. The conversation also touches on Cuba's role, international organizations, and the potential for infrastructure rebuilding in Venezuela, emphasizing the need for long-term strategies and careful risk management. Key highlights: Navigating Corruption and Security Risks in Business Banking and Money Laundering Concerns

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 the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes, Daniel Zmak, Senior Director of Product Marketing at Diligent to discuss the evolving landscape of compliance.    They explore the importance of modernizing compliance practices, addressing challenges like fragmentation and fatigue, and leveraging AI and technology to enhance efficiency. Key topics include the compliance maturity journey, connected compliance, and strategies for improving governance and oversight. With actionable insights and practical advice, this session aims to guide compliance professionals through the dynamic changes in the field.   Highlights Include   ·       Highs, Lows, and Surprises in Compliance ·       Compliance at an Inflection Point ·       The Compliance Maturity Journey ·       Fragmentation and Fatigue in Compliance ·       Connected Compliance: The Concept, Benefits and Future ·       AI in Compliance: Opportunities and Challenges ·     

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes Stephanie Font from Diligent delve into the intricate landscape of compliance challenges anticipated in 2026 and beyond. The discussion focuses on the dynamic regulatory environment, specifically around export control, sanctions, and vendor risk. Stephanie shares insights from her extensive background in due diligence, discussing how the scope and focus of due diligence have expanded over the years. The webinar covers compliance challenges associated with BIS and export control compliance, especially the affiliate rule, and the complexities surrounding China-related risk management. Additionally, they explore the DOJ National Security Division's Data Security Program and its impact on compliance. The session emphasizes the necessity of a robust process to manage regulatory instability, highlighting the importance of proactive documentation, risk audits, and continuous monitoring.  

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Kristy Grant-Hart, Head of Advisory Services at Diligent's Spark Compliance Group, to discuss where compliance has been in 2025 and where it is going into 2026. Tom Fox and Kristy Grant-Hart explore the future of corporate compliance in 2026 and beyond. Key discussion areas include the Trump administration's changing focus on the Foreign Corrupt Practices Act (FCPA), the designation of cartels as foreign terrorist organizations, and the implications for third-party due diligence. They also delve into modern slavery laws, the impacts of AI on compliance, and the necessity of a unified approach to compliance strategy. Additionally, Kristy introduces the Compliance and Ethics Innovation Collective, a new program from Spark and Diligent that integrates services and software to deliver a more robust compliance solution. The session concludes with strategic advice for compliance officers

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Nicole Di Schino, Principal Compliance Services Consultant at Diligent’s Spark Compliance Group, to discuss how best to harness AI for your compliance regime through 2026 and beyond. Nicole and Tom discuss the critical importance of AI governance, compliance, and modern GRC. They cover practical steps for developing comprehensive compliance programs, emphasizing the necessity for AI risk assessments, the establishment of AI governance committees, and the implementation of human oversight in AI processes. Nicole highlights the intrinsic risks of AI, including privacy concerns and AI bias, and shares her personal experiences with AI’s impact in educational settings. Tom underscores the role of compliance education, advocating for the broader view of compliance as an ambassadorial and academic function. This session also explores the integration of AI into compliance workflows and the es

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes Jim Massey who has recently release a new book, Risk in Action.  Jim Massey, an accomplished author and behaviorist practitioner, delves into the intricate dynamics of trust within leadership through his book "Risk in Action." Drawing from his extensive experience in high-stakes boardrooms and executive sessions, Massey emphasizes the crucial role of trust as a foundation for effective action. He explores the interconnected nature of trust, risk, and fear, urging individuals to redefine risk as a prioritization tool that enables progress and bold decision-making. By addressing these themes, Massey aims to spark vital conversations and empower leaders to embrace uncertainty, ultimately encouraging them to take courageous actions that drive growth and innovation.  Key Highlights   ·       Navigating Trust, Risk, and Fear in Leadership  ·       Enhancing Business Outcomes through Proa