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, including Gartner survey findings that 40% of employees would intentionally miss a compliance requirement to harm their organization, discussion of trust, employee sentiment, multi-generational communication differences, and the need to partner with HR while staying within organizational lanes;

(4) heightened third-party and supply chain risk expectations, including cybersecurity, tariffs/tariff evasion, export controls, and the need to unify siloed risk views into a holistic third-party risk assessment;

(5) anticipated increases in whistleblowing and investigation demands amid volatility, highlighting the importance of preventing retaliation, keeping reporters feeling heard through responsive communications, triage protocols, and anonymized case examples to build trust; and

(6) measuring program effectiveness through a shift from outputs to outcomes, including reviewing KPIs and key risk indicators, peer review of investigations, hotline “mystery shopping,” and gap analyses against the DOJ’s ECCP and compliance program hallmarks, with special emphasis on third-party documentation and ongoing monitoring.

Resources:

Mary Shirley on LinkedIn

Steph Holmes on LinkedIn

Matt Kelly at Radical Compliance

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Tom Fox

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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 criminal organization activities, Shah advises companies to integrate anti-money laundering processes into their compliance strategies to align with global anti-corruption efforts.

Key highlights:

Resources:

Anik Shah on LinkedIn

Sandisk

Tom Fox

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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 risks.

Key highlights:

Resources:

Marc Duncan on LinkedIn

Salus Solutions

Tom Fox

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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:

Resources:

Brent Carlson on LinkedIn

Red Flags Rising website

Tom Fox

Five-Part Blog Post Series on Doing Business in Venezuela on the FCPA Compliance and Ethics Blog

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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 Edge Presentation

·      AI and Compliance: A New Era

·      Risk Management in the AI Era

·      Expectations from the Leading Edge Conference

Resources

Compliance Week 

The Leading Edge: Applying AI and Data Analytics in E&C conference, click here. Compliance Week is offering a 20% discount to the event for listeners of this podcast. Use the discount code TFOX at registration.

Guests 

Matt Galvin on LinkedIn

Steptoe & Johnson

Host

Tom Fox

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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 financial institutions and private equity over compliance practices, as well as the long-term trend towards a more ethics-driven corporate culture.

Key highlights:

Resources:

Mike Volkov on LinkedIn

Volkov Law Group

Tom Fox

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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. Both guests express their eagerness to engage with compliance professionals and share practical insights to enhance the industry’s AI adoption.

Key highlights:

Resources:

Compliance Week

The Leading Edge: Applying AI and Data Analytics in E&C conference, click here. Compliance Week is offering a 20% discount to the event for listeners of this podcast. Use the discount code TFOX at registration.

 Guests

Roxanne Bras Petraeus on LinkedIn

Ethena

Andrew McBride on LinkedIn

Integrity Bridge

Host

Tom Fox

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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:

Resources:

Matt Ellis on LinkedIn

Miller & Chevalier LLC

Tom Fox

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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:

Resources:

Mike Volkov on LinkedIn

Volkov Law Group

Tom Fox

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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

·       Dynamic Compliance Programs

Resources

Daniel Zmak on LinkedIn

Diligent Website

Tom Fox

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