The Flood Book, BOA, COIs and China ABC Edition

Welcome to a revamped Everything Compliance. New host Adam Turteltaub and new panelist Rebecca Walker join returning regulars Matt Kelly and Karen Moore for the next iteration of Everything Compliance. Jonathan is on assignment this week. Tom Fox joins the EC Gang as a special guest panelist. Fan favs Shout Outs and Rants end this week’s episode. Karen Moore reviews China’s draft cross-border anti-corruption law, including mandatory compliance programs and reporting of suspected misconduct. She comments on the complexity of everyday life. Tom Fox discusses risk-management lessons from his latest book, Deluge Before Dawn. He shouts out to AI bots hanging out at dinner parties and Happy Hours. Rebecca Walker reviews COIs when senior execs or Board members oversee investigations of their colleagues. She shouts out about the recently released DOJ National Fraud Enforcement Division Directive and the information it provides compliance professionals. Matt Kelly looks at Bank of America’s $1.2B AML settlement. He rants about Tesla’s new flying car and shouts out to BJ Wholesale Club. Adam Turteltaub is our fearless leader. He shouts out to compliance professionals at non-financial institutions reviewing their AML programs and to the Milwaukee Brewers for beating his Dodgers to win their first World Series in 44 years. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Rebecca can be reached at Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance. We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Matt Kelly, Jonathan Armstrong, and Karen Moore for the next iteration of Everything Compliance. This episode features a cross-Atlantic discussion on emerging compliance issues. Fan favs Shout Outs and Rants end this week’s episode. Karen Moore looks at the growing Federal trend of bringing False Act Claims against corporate DEI programs. Jonathan Armstrong describes the first public GDPR report of an AI agent attack and offers nine responses. Rebecca Walker reviews key data from Navex anonymized disclosures, including COIs. Matt Kelly looks at recent guidance from the New York State Department of Financial Services on AI risk assessment. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Rebecca can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance. Host Adam Turteltaub and panelists Karen Moore, Matt Kelly, Rebecca Walker, and Jonathan Armstrong discuss compliance issues spanning DEI, executive orders, leadership support, and new EU sustainability rules. Karen Moore reviews rapid corporate reversals on DEI and cites a Stanford/UC Berkeley study, “Markets Do Not Punish Firms for Maintaining DEI”. Matt Kelly uses the “Lake Ontario to Lake America” renaming to argue executive orders aren’t laws binding companies and that choosing to comply reflects corporate values and policy-override decisions. Rebecca Walker argues “tone at the top” is insufficient without resources and real trade-offs, citing NAVEX data on gaps between encouraging, modeling, and persisting in ethics under pressure. Jonathan Armstrong outlines a new EU law limiting the destruction of unsold apparel and footwear, along with practical compliance steps. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Woody can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance. We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Jonathan Armstrong and Karen Moore for the next iteration of Everything Compliance. Matt is on assignment this week. This episode features a cross-Atlantic discussion on emerging compliance issues. Fan favs, Shout Outs, and Rants end this week’s episode. Karen Moore analyzes the DOJ’s $46M Veloxis Pharmaceuticals resolution, focusing on Sunshine Act misreporting caused by falsified expense data and the need to test controls for circumvention using analytics. Jonathan Armstrong warns that generative AI is driving more frequent, longer, more aggressive, and sometimes hallucinated whistleblowing and investigation communications, increasing complaints to regulators and burdening tribunals; he offers six tips, including awareness, checking for AI use, cautious AI adoption for workload, budgeting, restricting AI inputs for data protection, and improving AI literacy under the EU AI Act. Rebecca Walker reviews new developments in the KPMG Australia whistleblower controversy, highlighting investigation rigor, handling persistent whistleblowers with humility and curiosity, and the costs of getting investigations wrong. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Woody can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance. We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Matt Kelly, Jonathan Armstrong, and Karen Moore for the next iteration of Everything Compliance. Matt Kelly analyzes the Scoular Company FCPA enforcement action. Karen Moore reviews a recent pay discrimination case in Oregon. Jonathan Armstrong discusses the change of Prime Minister in the UK and what it means for compliance. Rebecca Walker looks at the current status of law and cases related to Board oversight. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Woody can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance. We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Matt Kelly, Jonathan Armstrong, and Karen Moore for the next iteration of Everything Compliance. Matt Kelly analyzes Bosch’s export controls violations involving Huawei under the foreign direct product rule, resulting in a $36 million BIS penalty, DOJ declination after self-disclosure, and major remediation hiring. Karen Moore covers the UK Commercial Payments Bill, aimed at protecting SMEs via a 60-day payment cap, mandatory late-payment interest, dispute-timing rules, a stronger Small Business Commissioner, and “name and shame” disclosures with potential ESG/fraud implications for supplier-treatment claims. Rebecca Walker shares NAVEX 2026 survey findings linking leadership “say vs. do” gaps to higher violations. Jonathan Armstrong covers a recent speech by the Director of the Serious Fraud Office, Graeme McNulty, who said the SFO intends to be a more active enforcer and to use the new failure-to-prevent-fraud offense with practical tips on policies, role-based training, fast tip-off response, properly resourced investigations, self-reporting, tone from the top, and third-party due diligence. Rebecca Walker focuses on speak-up culture, emphasizing post-report communications, lessons from KPMG Australia, and Navex data showing higher report volumes and longer investigation closure times. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Woody can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance. We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Matt Kelly, Jonathan Armstrong, and Karen Moore for the next iteration of Everything Compliance.  Matt Kelly highlights OFAC’s $1.05M settlement with FTI Consulting for indirectly providing services to sanctioned VTB Bank via a law firm payment conduit and creating a prohibited extension of debt when invoices went unpaid, emphasizing OFAC’s message that indirect dealings are treated like direct ones.  Karen Moore reviews the NFL Rooney Rule’s intent and criticism; the Brian Flores discrimination lawsuit, which is moving forward in open court after the Supreme Court declined to compel arbitration; and Florida’s attorney general’s subpoena challenging the rule under state civil rights law, alongside trends in discrimination charges and potential changes to EEO-1 data reporting.  Rebecca Walker shares NAVEX 2026 survey findings linking leadership “say vs. do” gaps to higher violations.  Jonathan Armstrong covers an Italian Garante fine (€190,000) against ITA Airways for overly broad digital forensics and GDPR process failures, underscoring the importance of scoping, vendor management, and documentation. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Woody can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a revamped Everything Compliance! We have a new host, Adam Turteltaub, and a new panelist, Rebecca Walker, who joins returning regulars Matt Kelly, Jonathan Armstrong, and Karen Moore for the next iteration of Everything Compliance. Jonathan Armstrong discusses BP’s leadership upheaval, shareholder ESG concerns, and recurring governance and tone-at-the-top issues, highlighting UK directors’ duties under Section 172 of the Companies Act. Karen Moore reviews IBM’s $17M DOJ False Claims Act settlement tied to alleged DEI-related practices, outlining the recent enforcement scaffolding, key alleged program elements, and ongoing risks beyond the settlement. Matt Kelly summarizes DOJ remarks on “algorithmic antitrust” risk, citing the RealPage litigation and warning that shared AI pricing tools can constitute cartel behavior, with heightened whistleblower incentives. Rebecca Walker explains the EU’s April 21, 2026, anti-corruption directive, which harmonizes offenses across 27 member states, including private bribery and “trading in influence,” large turnover-based penalties, and expected national transposition. The episode closes with brief shout-outs, rants, and themes of compliance culture. The members of Everything Compliance are: Rebecca Walker – a top legal mind in ethics and compliance. Woody can be reached at the law firm of Kaplan and Walker. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong – a UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Karen Moore, a principal at Sounding Board Compliance, can be reached at [email protected] The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to this Edition of award-winning Everything Compliance. In this episode, we have the quartet of Matt Kelly, Jonathan Marks, and special guests Lisa Fine and Dr. Hemma Lomax with Tom Fox, the Compliance Evangelist, as host. 1. Matt Kelly looks at the recent Millicom Cellular FCPA enforcement action.  He shouts out to the ChatGPT em-dash and rants about the federal government's attempts to ban all state regulation of AI.   2. Jonathan Marks reviews the failures of internal controls in the NBA and MLB around the ongoing betting scandals. He shouts out MacKenzie Scott for her $70 MM donation to Historically Black Colleges and Universities (HBCUs) in 2025, continuing her support after a $560 million donation to 27 HBCUs in 2020.  3. Special Guest Panelist Dr. Hemma Lomax considers where Agentic AI in compliance is heading. She rants about ChatGPT em dashes and shouts out recent legal tech conferences.   4. Special Guest Panelist Lisa Fine looks at three key issues on her mind about compliance for 2026. She shouts out to the Compliance Week survey, Inside the Mind of the CCO, and encourages all listeners to participate.   5. Tom Fox shouts out to GenZ and their play with the numbers 6,7, and traces the use of numerology in texts back to the Book of Genesis and the ancient text of Gilgamesh.  The members of Everything Compliance are: Karen Woody is one of the top academic experts on the SEC. Woody can be reached at [email protected] Matt Kelly is the Founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong is our UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Jonathan Marks can be reached at [email protected] Karen Moore is a principal at Sounding Board Compliance and can be reached at [email protected] The host, producer, and sometimes panelist of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at [email protected].  The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to this edition of award-winning Everything Compliance. In this episode, we have the complete quintet of Matt Kelly, Jonathan Armstrong, Karen Woody, and Karen Moore with Tom Fox, the Compliance Evangelist, sitting in as host. Matt Kelly looks at the recent EQS report assessing AI models for compliance. He shouts to Adam Turteltaub, who recently left the SCCE after 17 years. Jonathan Armstrong reviews AI risk relating to professional advice. He shouts out to Adam Turteltaub. Karen Moore delves into the recent EU parliamentary rejections of rolling back sustainability reporting. She shouts out to Accountancy Europe and Mother everywhere. Karen Woody looks at the recent Delaware Court of Chancery decision in the case of Brewer v. Turner and its impact on Caremark Doctrine claims. She shouts out to all those returning to work at the office. Tom Fox shouts out to Adam Turteltaub and Sean Connery. The members of Everything Compliance are: Karen Woody is one of the top academic experts on the SEC. Woody can be reached at [email protected] Matt Kelly, founder and CEO of Radical Compliance. Kelly can be reached at [email protected] Jonathan Armstrong is our UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at [email protected]. Jonathan Marks can be reached at [email protected] Karen Moore is a principal at Sounding Board Compliance, and can be reached at [email protected] The host, producer, and sometimes panelist of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at [email protected].  The award-winning Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices