FCPA Compliance Report

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.

FCPA Compliance Report is a business podcast hosted by Thomas Fox, with 1,000 episodes on record and a Required Pod Score of 80. PitchCentric scores this show on Booking Probability, Listen Score, and live audience signals refreshed every 24 hours.

Thomas Fox hosts FCPA Compliance Report, a business show with 1,000 episodes published.

Our AI reads these to draft pitches. Use them as grounding for a pitch that cites a real guest and a specific topic.

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  Episode #820

  Data Analytics in Compliance: Lessons from Scoular

  Aug 17, 202630 min

  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

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  Episode #819

  The Berko Verdict with Mike Volkov

  Aug 10, 202634 min

  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

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  Episode #818

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

  Aug 3, 202637 min

  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

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  Episode #816

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

  Jul 20, 202631 min

  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

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  Episode #815

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

  Jul 13, 202630 min

  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

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