Jeff Kushner on GRC Lessons from Kerrville 2025: Why a Policy Isn’t a Control

Innovation comes in many areas, and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance, as he speaks with top innovators, thinkers, and creators on the award-winning Innovation in Compliance podcast. In this episode, host Tom interviews GRC professional Jeff Kushner about Fox’s book Deluge Before Dawn and its risk management lessons from the 2025 Kerr County flood that killed 119 people. Kushner argues a policy is not a control: policies must be specific, operationalized, tested, monitored, and continuously improved, with clear roles, successor plans, training, and communication protocols. He contrasts document-centric assurance (having a written plan and passing inspections) with outcome-centric assurance (whether plans work in real conditions), citing Camp Mystic’s one-page “shelter in place” plan that passed a DSHS inspection two days before the flood. They discuss alerts as information that requires predetermined response sequences, the need for redundancies in communications, proactive scenario exercises (“what happens next?”), benchmarking against other sites like Mo Ranch, and board-level questions on impact, accountability, timelines, and measurable protections for life, property, and data. Kushner also describes his role at Allgress and its Rexina solution for identifying compliance and risk changes and guiding remediation. Key Highlights: Policy Versus Control Alerts and Control Steps Inspection Paradox Outcome-Based Assurance Scenario Testing Exercises Rexina and Allgress Board-Level Risk Questions Resources: Jeff Kushner on LinkedIn Allgress Allgress on LinkedIn Allgress/Rixena For a report Jeff Kushner created on the risk management issues we discussed in the podcast, click here. Tom Fox Instagram Facebook YouTube Twitter LinkedIn

Innovation comes in many areas, and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom interviews Dr. David Gruder, a clinical and organizational development psychologist. Dr. Gruder is trained in long-range master planning and is an ordained interfaith rabbi, bringing psychological and spiritual principles to business, culture, and compliance. He introduces “collaborative accountability” as a growth-oriented alternative to coercive, shame-based accountability and outlines four interlocking procedures: accountability-capable agreements, consistently elevating best practices, converting breakdowns into growth opportunities, and collaborative disengagement. He defines accountability as taking responsibility for the impacts of how one spends life energy on those to whom commitments are made, distinguishing good intentions from measurable commitments. Gruder describes three competing futures, regressionism, “Homo machina” transhumanism, and “Homo spiritus,” and urges leaders to align vision, mission, and ethics accordingly. He defines organizational nimbleness as resilience plus innovation and emphasizes marrying legal and psychological compliance. Key highlights: Spiritual Lens at Work Collaborative Accountability Why Psychology Matters Defining True Accountability Humanity’s Three Futures Business Ethics and Influence Resources: DrGruder.com TheCESS.com Facebook: @davidgruder / @drdavidgruder X (Twitter): @davidgruder LinkedIn: linkedin.com/in/gruder Instagram: @drgruder YouTube: @DavidGruder Tom Fox Instagram Facebook YouTube Twitter LinkedIn My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience. It is available on the following sites: Amazon.com Stoney Creek Publishing Barnes and Noble Texas A&M University Press Bookshop.org Google.Books Walmart Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts

Innovation comes in many areas and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance as he visits with top innovative minds, thinkers and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom welcomes Pamela gupta, the author of De-Risking AI Adoption: The AI Trust Layer: An AI Governance Playbook.   Pamela Gupta, is the founder of Trusted AI and author. She and tom discuss the closing the AI governance implementation gap between high-level frameworks (e.g., NIST AI RMF, ISO 42001) and use-case execution under rapid AI rollout pressure. Gupta argues organizations struggle to translate principles into actionable, risk-based decisions involving many stakeholders (security, privacy, legal, audit, business, IT, data science), leading either to unmanaged risk or stalled innovation. She emphasizes AI-specific risks such as bias, transparency, explainability, and accountability, illustrating with Humana’s nH Predict claims system (alleged bias; 90% reversals) plus Amazon’s scrapped hiring model and Air Canada’s chatbot ruling. Gupta outlines her AI TIPS framework (eight pillars, ~80 controls) and contends AI governance can accelerate adoption by defining intake, evidence, and decision processes, even as agentic AI raises risk and uncertainty.  Key Highlights  ·      AI Governance Gap ·      Assessing AI Risk ·      Bias and Ethics Ownership ·      Humana Case Study ·      AI TIPS Framework ·      Governance as Accelerator  Resources Pamela Gupta on LinkedIn De-Risking AI Adoption: The AI Trust Layer: An AI Governance Playbook Website: TrustedAI.AI Podcast: Trustworthy AI: De-Risk Business Adoption of AI Trusted AI Feed: TrustedAI.AI/feed/ X/Twitter: @OutsecureCom LinkedIn: OutSecure Inc. YouTube: OutSecure Inc. Facebook: OutSecure Inc.     Tom Fox Instagram Facebook YouTube Twitter LinkedIn   My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County Texas which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival and resilience. It is available on the following sites:    Amazon.com Stoney Creek Publishing Barnes and Noble Texas A&M University Press Bookshop.org Google.Books Walmart  Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts  

Innovation comes in many areas, and compliance professionals need to not only be ready for it but also embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom welcomes Doni Hoti, co-founder and CEO of Adclear. Hoti brings a fascinating perspective on embedding compliance directly into content creation. He begins with the shift in advertising and marketing compliance from a slow, “checkpoint” back-office function to an embedded, revenue-enabling capability. Hoti explains that modern content creation involves many stakeholders and must move at near-real-time speed, while enforcement risk and the cost of losing customer trust keep rising. He describes how AI has broken traditional review models by increasing both content volume and speed expectations and how Adclear uses horizon scanning across global regulators, agentic AI, and company-specific policies to deliver more deterministic, auditable compliance guidance tied to rulebooks. Fox and Hoti then turn to third-party and affiliate challenges, regulator-ready documentation and audit trails, and business outcomes such as reduced review SLAs, scalable approvals, and revenue uplift, with marketing increasingly owning the process alongside legal and compliance. Key highlights: Compliance Disconnect Trust and Shopfront Embed Compliance Third-Party Risks AI as Solution Audit Trail Proof Resources: Adclear Doni Hoti on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience. It is available on the following sites: Amazon.com Stoney Creek Publishing Barnes and Noble Texas A&M University Press Bookshop.org Google.Books Walmart This week only, the Kindle e-book version is available for $0.99 on Amazon.

Innovation comes in many areas, and compliance professionals need to not only be ready for it but also embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom welcomes Michelle Tavares, a former federal government forensic accountant and former USCIS EB-5 compliance officer who helped rewrite the EB-5 statute into the Reform and Integrity Act (RIA). Michelle Tavares brings a rare blend of forensic accounting, securities litigation, and federal investigative experience to her perspective on EB-5 visa program compliance and adjudication. Having worked on white-collar crime matters and immigration policy, and as a compliance officer for the EB-5 program, she helped shape the Reform and Integrity Act, which strengthened oversight, penalties, and investor protections. Tavares believes the old EB-5 framework lacked meaningful enforcement, and she argues that USCIS now properly scrutinizes regional centers, attorneys, and related parties through background checks, AML/KYC review, and a broader integrity lens. From her viewpoint, successful EB-5 filings depend on consistent, credible evidence across immigration, securities, banking, and governance issues, with better guidance helping honest organizations avoid preventable compliance mistakes. Key highlights: EB5 Compliance, Penalties, and AML-KYC Overhaul Four lenses on every EB5 transaction Preponderance of Evidence in EB-5 Compliance Narratives Vetting vendors, promoters, and experts for EB5 compliance Resources: Standard & Proof Investigations Counsel Ready Michelle Tavares on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience. It is available on the following sites: Amazon.com Stoney Creek Publishing Barnes and Noble Texas A&M University Press Bookshop.org Google.Books Walmart This week only, the Kindle e-book version is available for $0.99 on Amazon. Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts

Innovation comes in many areas, and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom welcomes Mara Senn, Founder and CEO of Ethakos. What is innovation in compliance? Mara Senn certainly shows it in this podcast. Her path to founding Ethakos spans Big Law, early FCPA and anti-corruption work, investigations at the World Bank, and senior in-house compliance roles at major Fortune 500 companies. That experience gave her a clear view of the everyday frustrations compliance teams face, especially clunky tools, dirty data, and rigid workflows that slow down real investigations. She built Ethakos as an AI-native, highly configurable platform to solve those pain points, using “vibe coding” with Claude to move quickly while keeping human judgment at the center of every decision. In her view, the platform reflects a simple but powerful idea: AI should make compliance work faster and cleaner, not replace the expertise and risk-based thinking that good compliance professionals bring. Key highlights: Vibe coding Ethakos through dozens of decisions Start with actionable hits, not meaningless alerts AI-generated first drafts for chronologies and interviews Audit logs and document-linked investigative credibility Tech-forward compliance teams identifying 13 risks instead Resources: Ethakos Mara Senn on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience. It is available on the following sites: Amazon.com Stoney Creek Publishing Barnes and Noble Texas A&M University Press Bookshop.org Google.Books Walmart This week only, the Kindle e-book version is available for $0.99 on Amazon.

Innovation comes in many areas, and compliance professionals need to not only be ready for it but also embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom speaks with Bennett Borden of Clarion AI Partners. Borden is a lawyer and data scientist whose career has long focused on the intersection of law, data, and technology, including AI governance, compliance, and the legal implications of generative AI. Drawing on experience at the CIA, in big law, and leading AI-focused legal practices, he views generative AI as a disruptive force reshaping both legal services and business models. Borden argues that effective AI governance requires “governance engineering”: translating legal obligations into technical controls and measurable proof of compliance rather than treating compliance as a separate burden. He also encourages lawyers and organizations to embrace AI proactively, using it to build more efficient, future-ready practices while managing risk through practical, system-level safeguards. Key highlights: AI-Driven Law Practice Beyond the Billable Hour Compliance as guardrails for faster innovation Gift, Travel, and Entertainment Sandbox Projects Trust Built by Enterprise Licenses and Safeguards Microsecond-by-Microsecond Compliance Proof for AI Governance Resources: Bennett Borden on LinkedIn Clarion AI Partners Website Clarion AI Partners on LinkedIn Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts

Innovation comes in many areas, and compliance professionals need to not only be ready for it but also embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom visits with Paul F. Welter, co-founder at Bayshore AI. Welter is a German-qualified lawyer whose path into legal innovation began with an early background in software engineering, giving him a rare combination of legal and technical expertise. That experience led him to study how legal reasoning could be automated at Stanford Law School’s Codex, and later to co-found Bayshore AI to build LLM-based tools for in-house legal and compliance teams. He believes AI can help scale legal and compliance support because demand far exceeds human capacity, but he expects adoption to happen gradually through copilots, policy chatbots, and targeted workflow automation rather than a sudden transformation. At the same time, he stresses that regulated companies need systems that are transparent, auditable, and able to show how decisions are made, with human oversight remaining essential for higher-risk matters and regulator-facing accountability. Key highlights: AI Legal Reasoning for Embedded Compliance Workflows Auditable Legal Decision Logic from Conventional Programs Customer-Specific Policy Logic with Deterministic Compliance Logic translated into code for reviewable decisions Full-time employee days of manual compliance checks AI copilots, compliance workflows, and decision trails Resources: Paul Welter on LinkedIn Bayshore Website Bayshore on LinkedIn Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts

Innovation comes in many areas, and compliance professionals need to not only be ready for it but also embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom visits with Brian Holyfield, Co-Founder & Chief Product Officer at SendSafely. Holyfield discusses why the right compliance question on cybersecurity is not whether a breach will happen but when and what data will be exposed, often through vendors. He explains “blast radius” as the scope of access and data reachable during an incident and argues organizations should prioritize architecture, data minimization, and retention controls alongside prevention. He also highlights risks from accumulated file attachments, overbroad user access, interconnected systems using OAuth tokens, and “standing access” via long-lived machine credentials that can be abused without obvious login anomalies. Holyfield discusses examples involving ServiceNow and Salesforce that illustrate platform vulnerabilities, trusted upstream vendor connections, and end-user compromise, and advises leaders to inventory connections, define retention/archiving, and move sensitive data out of frontline platforms; SendSafely positions itself as an end-to-end encrypted trust layer, including for AI chatbot attachments. Key highlights: Assume the Breach Blast Radius Explained ServiceNow and Salesforce Lessons Board-Level Questions AI Changes the Game Compliance and Governance Fit Resources: SendSafely Brian Holyfield on LinkedIn Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts

Innovation comes in many areas, and compliance professionals need to not only be ready for it but also embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox visits with Clarence Chio, co-founder and CEO of Coverbase, about modernizing third-party risk management as AI reshapes vendor due diligence. Chio describes how traditional onboarding relies on long questionnaires, SOC 2/ISO documentation, and trust centers that streamline document exchange but were built for human-driven workflows. He argues AI makes the process risky and increasingly meaningless because vendors can auto-complete questionnaires convincingly and customers can analyze them with AI, eroding the value of nuance and attestation. Chio contrasts static, point-in-time evidence with the need for dynamic, continuous security evidence, noting software changes faster than annual assessments and third-party software frequently appears in breach chains. He proposes moving from check-the-box questionnaires to first-principles risk validation, including continuous information sharing, deeper technical evidence, and machine-readable artifacts such as SBOMs. He highlights Coverbase’s open-source Trust MCP, which provides scoped, standardized access to verified vendor evidence for an agent-driven future. Key highlights: Why Coverbase Exists Trust Centers Explained AI Makes Due Diligence Risky Attestation and Human Loop Static vs. Dynamic Evidence Machine-Readable Trust Future Resources: Coverbase Clarence Chio on LinkedIn Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts