FCPA Compliance Report

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.

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Cartels, TCOs and Compliance in Latin America, July 20-21

Matt Ellis on LinkedIn

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The FCPA Compliance Report was recently named the world’s best business ethics podcast by FeedSpot.

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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.

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Gerry Zack on LinkedIn

RiskTrek

Eastward AI

Tom Fox

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The FCPA Compliance Report was recently named the world’s Best Business Ethics Podcast by FeedSpot.

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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:

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

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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.

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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:

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

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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.

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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.

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Archive360

George Tziahanas on LinkedIn

Tom Fox

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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:

Resources:

Invitational Selling: The Human Connection Advantage

Dr. Dennis Cummins on LinkedIn

 Tom Fox

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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.

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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:

Resources:

Cartels, TCOs and Compliance in Latin America, July 20-21

Matt Ellis on LinkedIn

Tom Fox

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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.

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In this episode, Tom Fox takes a solo turn behind the mic to report on the AI tracks from the recently concluded Compliance Week 2026 conference.

He highlights two AI tracks: practical “creative” uses, including live demonstrations by Hemma Lomax creating PowerPoint content and Roxanne Petraeus creating video content, and the more critical compliance focus on AI governance, oversight, and accountability amid limited federal direction and a growing patchwork of state laws, with the EU AI Act positioned as a global benchmark. Tom emphasizes applying standard compliance risk management to AI (identify, manage, train, implement, monitor, improve), addressing shadow AI, internal/external/vendor risks, and building AI “in” rather than bolting it on. He notes scaling challenges, ROI questions, auditor expectations, risk registers, fraudsters’ use of AI, and ongoing discussions with Matt Kelly.

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For more information on the use of AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on Amazon.com: https://a.co/d/00XNoelh.

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: https://a.co/d/05NTW4zz.

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In this episode, Tom Fox welcomes Edye Edens about launching her Life Sciences Law Group (“Eedee Law”) after years of contracting in life sciences compliance across multiple firms.

Edye explains she founded the firm to better align her practice with supporting clinical trial sites, vendors, and academia, which often lack the budgets and in-house legal resources of sponsors and CROs. She describes a multidisciplinary team model that includes non-attorney quality, TMF, regulatory, and inspection-readiness professionals with deep study-operations experience, enabling rapid, practical support at different price points, including fractional engagements and urgent FDA inspection support. Edye outlines four core client segments: independent sites/site networks, academic medical centers’ research compliance functions, NCI-designated cancer centers, and vendors entering clinical trials who need guidance on Part 11, HIPAA, QMS, and vendor qualification. She discusses growing AI-related client needs, emphasizing evolving regulatory expectations and “compliance at the speed of business,” and shares how to connect via website, LinkedIn, and email.

Key highlights:

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Edye Edens on LinkedIn

Eedee Law

Tom Fox

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

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.

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In this episode, Tom Fox welcomes Matt Friedman, founder and CEO of The Mekong Club, to discuss his book “Awakening the Advocate,” which explains his career in the fight against human trafficking.

Matt tells his journey through survivor/NGO stories, traces his personal journey from a shy child in Connecticut to 35 years of anti-slavery work across 35+ countries, and shows that ordinary people can become advocates. He assesses progress as limited relative to the scale of the problem (50 million in modern slavery; 110,000 helped; 6,000 convictions; $236B in profits vs. $400M, now $250M, to fight it), arguing that awareness is the main gap. He outlines how companies, especially banks, can start internally via leadership briefings, policies, awareness, targeted training, red flags, procurement review, and baseline assessments, linking efforts to ESG, business value, and reputational/regulatory risk. Matt also discusses AI’s emerging role in detecting patterns across supply chains and transactions and emphasizes individual actions, pro bono support, and the importance of compliance work.

Key highlights:

Resources:

Matt Friedman on LinkedIn

The Mekong Club

Awakening the Advocate on Amazon.com

Tom Fox

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

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.

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