Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes Ellen Lafferty, a well-known figure in the compliance community with a distinguished career in both financial and educational institutions. Ellen discusses her new book, ‘Anti-Bribery and Corruption Law and Compliance In a Nutshell,’ detailing what inspired her to write it and how it can serve as a comprehensive reference for both legal and compliance professionals. They explore Ellen’s transition from litigator to in-house compliance officer, emphasizing the importance of understanding the ultimate audience in legal advice. They also discuss the implications of recent changes in FCPA enforcement priorities by the U.S. government as of 2025 and how compliance professionals should adapt. Ellen emphasizes the importance of maintaining rigorous compliance programs and provides practical guidance on conducting self-assessments and gap analyses to ensure robust anti-bribery and corruption measures. Key highlights: Ellen Lafferty’s Career and Book Inspiration Transition from Litigator to Compliance Officer Scope and Audience of the Book Current Compliance Landscape in 2025 Advice for Compliance Professionals Resources: Ellen Lafferty on LinkedIn West Academic Publishing Anti-Bribery and Corruption Law and Compliance in a Nutshell on Amazon Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes Peter Schablik, a seasoned professional in risk consulting and fraud detection. Peter shares his extensive background, including his transitions from consulting to audit and his experiences across various industries. The discussion explores the significance of fraud detection, critical thinking, and strategic fraud mitigation. Key topics include the role of management in fraud prevention, common misconceptions about fraud controls, technological and management overrides, and industry-specific fraud patterns. Peter also emphasizes the importance of basic controls, such as the segregation of duties, the need for a clear tone at the top, the effective use of hotlines, and thorough third-party risk assessments. Peter emphasizes the value of instinctual and behavioral analysis in fraud investigations, providing actionable advice for strengthening an organization’s fraud prevention program. Key highlights: The Importance of Fraud Detection and Mitigation Common Misconceptions About Fraud Patterns of Fraud Across Industries Segregation of Duties and Basic Controls Investigative Strategies and Behavioral Cues Strengthening Fraud Prevention Programs Resources: Peter Schablik on LinkedIn Want to Catch a Fraudster? Think Like a Cop Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, see my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy, and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode, Tom Fox is joined by Tom Hardin, a former hedge fund analyst known as Tipper X, who shares his unique journey from insider trading informant to a global speaker on compliance and risk. Hardin previews his upcoming panel on applying behavioral science to design effective GRC programs at the #RiskNYC conference. He discusses topics such as cognitive biases, social norms, and rationalizations in decision-making, emphasizing the enduring nature of human behavior despite technological advancements. The episode highlights Hardin’s goal of fostering deeper connections between psychology, technology, and regulation to build more proactive and resilient risk cultures. Resources: #Risk Conference Series #RiskNYC—Tickets and Information Tom Hardin on LinkedIn Visit Tipper X Website Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode of the Risk New York podcast series, Tom Fox introduces the upcoming Risk New York Conference, scheduled for July 9-10 at Fordham Law School. The conference, hosted by GRC World Forums, will focus on various aspects of risk management, including AI, tech risk, financial and crypto risk, and GRC frameworks. Tom discusses his keynote based on his book ‘Upping the Game’ and highlights key speakers and exhibitors, including Robert Clark from Howard University, Bill Coffin and Erica Alburn from Ecosphere, and Michael Rasmussen, known as the father of GRC. The episode highlights the importance of the conference and provides details on discounted tickets, as well as other information available in the show notes. Resources: #Risk Conference Series #RiskNYC—Tickets and Information Compliance Podcast Network Website Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode, Tom Fox is joined by Erica Salmon Byrne, Chief Strategy Officer and Executive Chair at Ethisphere, and Bill Coffin, Editor-in-Chief at Ethisphere. The conversation delves into their roles in the compliance community, focusing on their work with the Ethicast Reacts series. They discuss how they analyze news stories to extract compliance lessons, help organizations understand and mitigate risks, and create storytelling opportunities to advance compliance programs. They also share their excitement for their upcoming presentation at the Risk New York City conference, where they’ll engage with professionals from diverse backgrounds. Resources: #Risk Conference Series #RiskNYC—Tickets and Information Erica Salmon Byrne on LinkedIn Bill Coffin on LinkedIn Ethisphere Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes back James Tillen and Ann Sultan, both partners at Miller & Chevalier, and takes a deep dive into four recent DOJ policy announcements: FCPA Enforcement, White-Collar Enforcement, Criminal Enforcement Policy, and the Whistleblower Pilot Program. They take a deep dive into Deputy Attorney General Todd Blanche’s memo on Investigations and Enforcement of the FCPA, reviewing the stated main goals of the DOJ and how prosecutors are supposed to achieve these goals. They also consider three directives to prosecutors: focus on cases involving individual misconduct, proceed expeditiously, and consider the collateral consequences. They also examine the White Collar Plan and CEP and ask if we have shifted from a presumption of declination to a more tangible framework and conclude by reviewing what compliance professionals need to consider and investigate now. Key highlights include: How does the principle of “not attribute[ing] nonspecific malfeasance to corporate structures” impact potential prosecutions of companies and individuals? And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations? What does it mean for companies that the DOJ is prioritizing “serious misconduct”? What are the implications of the DOJ’s stated intent to avoid penalizing “routine business practices in other nations”? Do you see this as a shift in focus for the DOJ to non-US companies? Other DOJ Priorities & Announcements Policy Shifts and Clarifications Looking Ahead: What’s on the Horizon Resources: FCPA Spring Review 2025 – Miller & Chevalier DOJ Criminal Division White Collar Plan Guidelines for Investigations and Enforcement of the FCPA Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in compliance programs, see Tom Fox’s new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode, Tom Fox talks with Chris Mason, who recently launched his risk advisory practice, Woodhorn Global, focusing on due diligence investigations. Chris shares insights about his upcoming presentations at the #RiskGRC conference in July, focusing on AI investments and the impact of political uncertainty on the GRC (Governance, Risk, and Compliance) community. They discuss the significance of AI in the field and the importance of adapting to political changes. Chris also emphasizes the value of in-person events in understanding best practices and navigating the evolving risk landscape.  Resources: #Risk Conference Series #RiskNYC—Tickets and Information Chris Mason on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy, and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode, Tom Fox talks with Gwen Hassan, the Chief Compliance Officer for Unisys Corporation, about her role and the upcoming #RiskNYC conference. Gwen shares insights into Unisys’ operations, including the various technologies and services they provide, and highlights her responsibilities in managing global ethics, compliance, and trade compliance risks. She also gives a teaser about her panel presentation on the compliance and ethics risks associated with artificial intelligence, stressing the importance of understanding AI’s impact on company culture and regulatory compliance. Gwen expresses her excitement about the conference, emphasizing the value of engaging with fellow risk management experts. Resources: #Risk Conference Series #RiskNYC—Tickets and Information Gwen Hassan on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode, Tom Fox welcomes Michael Rasmussen, a renowned expert in Governance, Risk Management, and Compliance (GRC), often referred to as the ‘father of GRC.’ Michael shares insights into his contributions to the field, including his work with the SEG GRC Capability Model. The conversation highlights Michael’s anticipated presentation on ‘The Future of GRC’ at the upcoming risk conference in New York City. Drawing inspiration from Star Trek (TOS, and how can you not love that?), Michael emphasizes the importance of managing business risks effectively. The discussion also touches on the benefits of face-to-face interactions and networking opportunities at such conferences. Resources: #Risk Conference Series #RiskNYC—Tickets and Information Michael Rasmussen on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Join Tom Fox and hundreds of other GRC professionals in the city that never sleeps, New York City, on July 9 & 10 for one of the top conferences around, #Risk New York. The current US landscape, shaped by evolving policies, rapid advancements in AI, and shifting global dynamics, demands adaptive strategies and cross-functional collaboration. At #RISK New York, you will master the New Regulatory Reality by getting ahead of US regulatory shifts and their impact. Conquer AI and Tech Risk by Safeguarding Your Organization in an AI-Driven World and Understanding the Implications of Major Tech Investments. Navigate Financial and Crypto Volatility by Protecting Your Assets and Exploring Solutions in a Dynamic Market. Strengthen Your GRC Framework by Leveraging Governance, Risk, and Compliance for Strategic Advantage. Protect Digital Trust by addressing challenges in cybersecurity and data privacy, and combating misinformation. All while meeting with the country’s top #Risk management professionals. In this episode, Tom Fox talks with Matt Kelly about his presentation on the importance of understanding how AI can be productively adopted within enterprises, as well as the ethical challenges it presents, including discrimination and data validity. Matt also discusses the importance of AI governance and offers a preview of his upcoming presentation on this topic. Matt expresses his eagerness to engage with other GRC professionals at the forthcoming conference to exchange ideas and discuss emerging risks in third-party and vendor risk management. Resources: #Risk Conference Series #RiskNYC—Tickets and Information Matt Kelly on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices