FCPA Compliance Report

Episoder

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  Mike Huneke and Brent Carlson with US Attorney David Metcalf 19.10.2026 38min

  In this episode, Tom Fox cross-posts an episode of Red Flag Rising featuring U.S. Attorney for the Eastern District of Pennsylvania David Metcalf, joined by co-hosts Mike Huneke and Brent Carlson. David Metcalf, the U.S. Attorney for the Eastern District of Pennsylvania, brings a practical, business-aware perspective on fraud enforcement and corporate compliance, shaped by experience both in government and as in-house counsel. He notes that white-collar enforcement in his district centers heavily on healthcare fraud but also extends to cybercrime, narcotics trafficking, export controls, and other complex investigations. Metcalf strongly encourages companies to consider self-disclosure in their self-interest, warning that the DOJ will be especially aggressive toward those that do not come forward. At the same time, he stresses that early engagement is the most effective approach, because trust and candid discussion at the outset can create meaningful benefits, including even unpublicized declinations.  Key highlights: Risk-based compliance shaped by business realities Whistleblower evidence versus compliance rationale perspective Data Analytics-Powered National Fraud Detection Center Data-Driven Detection of Healthcare Fraud Cases Tariff Evasion and Customs Fraud Crackdown DOJ’s relaxed near-miss voluntary disclosure incentive Resources: More about U.S. Attorney David Metcalf The Eastern District of Pennsylvania’s White Collar Justice Program The DOJ’s National Fraud Enforcement Division More about the 1950 classic Japanese film “Rashomon” Contact Brent: [email protected] More about Brent Connect with Brent on LinkedIn Contact Mike: [email protected] More about Mike Connect with Mike on LinkedIn Tom Fox Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: John Capodice on Disaster Recovery’s Blind Spot: Planning for Access 12.10.2026 10min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from front-line experts, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. Tom interviews John Capodice, Executive Vice President at Sterling Site Access Solutions, about Sterling’s role in disaster recovery when utilities face anomalous events and need to restore power rapidly. Capodice previews his Disaster Expo presentation on quickly deploying safe temporary roads, bridges, and man-camp platforms, explaining Sterling’s capabilities as the world’s largest manufacturer of matting and access products to create stable access when storm-damaged ground or unsafe crossings prevent entry. He emphasizes a common “blind spot” in disaster recovery: access is often the first victim of a storm, and planning reduces time lost and costs. Sterling offers pre-incident consulting to identify weak spots, establish MSAs, and support utilities, co-ops, and other sectors, including wind, solar, and civil projects, with safe, efficient work platforms. Resources: Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Steph Holmes on Managing the Long Tail of Hotline Reports 12.10.2026 25min

  In this episode, Tom Fox welcomes back his friend and colleague Steph Holmes of EQS Group. They take a deep dive into the “long tail” of hotline/whistleblower reports and why retaliation risk persists after an investigation closes, serving as a key indicator of organizational culture. Holmes recommends starting with a retaliation-specific risk assessment, especially as EU whistleblower rules shift the burden to employers to prove they did not retaliate. They discuss creating scalable, risk-based visibility into significant post-complaint employment actions (e.g., termination, demotion, compensation, RIF selection) while sharing only minimum necessary context, emphasizing timing, decision-maker involvement, prior retaliation concerns, and strong documentation. Holmes highlights less obvious retaliation signals (negative review shifts, exclusion, increased scrutiny, unfavorable assignments) and suggests periodic check-ins, pulse surveys, and potential AI-enabled trend detection. They also stress training managers to “listen up,” respond appropriately, and escalate concerns, and to use feedback to improve speak-up confidence. Key highlights: Hotline Long Tail Retaliation Risk Assessment RIF And Confidentiality Gaps Subtle Retaliation Signals Training Managers Culture Impact And Feedback Resources: Steph Holmes on LinkedIn EQS Group  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 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: Rob Borse on AI in Emergency Management 09.10.2026 9min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from front-line experts, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. Tom interviews Rob Borse about his talk “Artificial Intelligence & Emergency Management: Hype, Reality, and the Road Ahead.” Borse has recently retired from Dallas Fire Rescue and the City of Dallas. He has 26+ years of experience in operations and executive strategy and now serves as an independent advisor on public safety strategy, technology, data, and predictive analytics. Borse previews his conference session, aiming to separate AI hype from practical use cases and highlight under-discussed risks. He outlines potential applications in planning, intelligence, situational awareness, public information, damage assessment, and resource management, while emphasizing concerns including hallucinations, bias, privacy, cybersecurity, and overreliance on algorithms. He also raises resilience issues tied to AI infrastructure, such as data centers’ power and water demands, fire protection, supply chains, and continuity planning, and urges multidisciplinary, cross-jurisdictional dialogue. He hopes to learn, connect, and contribute at the conference. Resources: Connect with RobBorse on LinkedIn Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: Susan Anderson on an Animal-Inclusive Disaster Response 08.10.2026 11min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from front-line experts, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. Tom Fox interviews Susan Anderson, Senior Director of Disaster Response at the American Society for the Prevention of Cruelty to Animals (ASPCA), about integrating animals into emergency management throughout the disaster life cycle. Anderson explains how her team supports local, state, and national agencies with animal-inclusive planning and provides resources when communities are overwhelmed by events such as severe weather and wildfires. She notes animal inclusion still varies widely by jurisdiction and cites Hurricane Katrina as a turning point that highlighted the human-animal bond and the consequences of excluding pets. Anderson argues that human and animal survival are interdependent and that an all-hazards, all-species approach improves public safety and responder safety, increases shelter capacity, and reduces secondary public health risks. She discusses shelter overcrowding limiting evacuation “safe harbor” options and urges local engagement through fostering, donating supplies, and legislative outreach. She previews advancing these topics at Disasters Expo. Resources: Connect with Susan Anderson on LinkedIn Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: Adam Lee on Making the Case for Resilience in Healthcare 07.10.2026 8min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from front-line experts, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. In this speaker series, Tom Fox interviews guest Adam Lee, Director of Emergency Management & Organizational Resilience at Memorial Hermann Health System. Lee describes overseeing emergency management preparedness, business continuity, and operational continuity and shares highlights from his talk, “Making the Case for Resilience in Healthcare.” He argues resilience is no longer about if but when, especially as health systems with small margins must still function during disasters to serve their communities and fulfill their mission. Lee notes resilience requires cross-functional collaboration and extends beyond IT into operations, workforce, facilities, and overall organizational functioning, with evolving threats including hurricanes, cyber risks, and mass casualty events. He hopes to learn from other speakers, gain new perspectives, and expand professional networks. Resources: Connect to Adam Lee on LinkedIn Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: Amy Forsythe on Crisis Leadership and Media Communication 06.10.2026 11min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from front-line experts, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. In this speaker series, Tom Fox interviews retired US Navy Reserve officer Amy Forsythe ahead of her Disaster Expo keynote, “When Crisis Calls: Leadership, Communication & Community in the Moments That Matter.” Forsythe describes her 33 years of service, beginning as a Marine Corps combat photographer and later retiring as a Navy public affairs officer, with extensive experience coaching senior leaders on media engagement and crisis response. She and co-presenter Mandy Feindt will combine Feindt’s firsthand experience from the Red Hill fuel spill crisis in Hawaii with Forsythe’s lessons on building trust, honest communication, humility, and effective interagency coordination during disasters. Forsythe notes these principles apply to businesses and leaders whose viability can be impacted by crisis communication, including the risk of “one bad interview.” She aims to share hard-learned lessons, including from the 2017 Santa Rosa, California, fires, and to connect with practitioners in Houston. Resources: Connect with Amy Forsythe on LinkedIn Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Dr. Joseph Colaco Reducing Hurricane Damage in Houston’s High-Rise Environment 05.10.2026 10min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from front-line experts, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. In this speaker series, Tom Fox interviews Dr. Joseph Colaco about Reducing Hurricane Damage in Houston’s Expanding High-Rise Environment. Dr. Colaco is a tenured University of Houston architecture professor and president of Dr. Colaco Engineers. He visits with Tom about his upcoming presentation on reducing hurricane damage in Houston’s growing high-rise environment. Dr. Colaco describes assessing building performance during Hurricane Alicia in 1983, including firsthand observations downtown, documentation of facade damage, and visits to the Galleria area and Galveston. He explains that Houston’s increased density and taller buildings create new wind-flow conditions, making some older wind-tunnel results less applicable; he notes Houston began wind-tunnel and window-wall facade testing in the 1970s to inform design and construction. Dr. Colaco values conferences for networking and for transferring lessons learned across generations and cites Chicago’s periodic inspection requirements for tall buildings as a model for improving building safety and living conditions in Houston. Resources: Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  IIA President Anthony Pugliese on the IIA’s Expanding Role in AI, Cybersecurity, and Geopolitical Risk 05.10.2026 27min

  In this episode, Tom Fox welcomes Anthony Pugliese, President and CEO of The Institute of Internal Auditors Inc. We begin with the IIA’s global footprint, with boards in 122 countries; its role in setting internal audit standards; certifications, including the Certified Internal Auditor credential with about 225,000 holders; and education. Pugliese describes how internal audit is shifting from primarily financial controls to a broader focus on non-financial risks, including cybersecurity, AI and disruptive technologies, sustainability reporting, business resilience, and geopolitical risk. He emphasizes internal audit’s growing prospective/advisory role, particularly in assessing whether AI governance is keeping pace with rapid adoption and in communicating complex risks to boards and audit committees. Cybersecurity is cited as chief audit executives’ top concern and increasingly requires continuous monitoring. Pugliese notes members want more industry-specific guidance and expanded GRC resources relevant to compliance and directs listeners to iia.org and the free annual Risk in Focus report. Key highlights: What the IIA Does Risk Landscape Shifts From Assurance to Advisory Geopolitical Risk in Practice Cyber Threats and Continuous Auditing Why Compliance Pros Should Join Resources: Anthony Pugliese on LinkedIn Institute of Internal Auditors  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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: James Caron on Lessons from Winter Storm Uri 02.10.2026 10min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from experts on the front lines, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. In this speaker series, Tom Fox interviews James Caron on Lessons from Winter Storm Uri and Business Risk Preparedness. James Caron is the director of weather operations for North America at Atmospheric G2 and owner of Caron Weather Consultancy. He discusses his upcoming Disaster Expo 2026 presentation in Houston, “Storm Ready: Analyzing Winter Storm Uri and Preparing for Future Winter Hazards.” Caron explains forensic meteorology as expert witness work in litigation involving weather-related incidents, then outlines how a displaced polar vortex during Uri placed all 254 Texas counties under winter storm warnings, drove Dallas–Fort Worth to -2°F, nearly collapsed ERCOT, cut power to about 4.5 million customers, and spiked natural gas prices above 1,000 MMBTU. He will use his financial institution lead-time forecasting experience as a case study and offer practical preparedness guidance for emergency management, grid and energy operators, and businesses, noting that Uri broadened business awareness of winter risk and that a strong El Niño could elevate winter 2026/27 threats. Resources: Connect with James Caron on LinkedIn Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: Mike Mulligan on Lessons from Harvey 01.10.2026 13min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there’s no better place. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from experts on the front lines, and meet the partners who will help you turn preparedness into action. Whether you’re here to learn, share, or collaborate, you’re part of the effort to build a more resilient nation. In this speaker series, Tom Fox interviews Atascocita Fire Department Chief Mike Mulligan about Hurricane Harvey Frontline Leadership Lessons. Chief Mulligan serves the Atascocita Fire Department, which covers a 25-square-mile area with 75,000–90,000 residents in unincorporated northeast Harris County. Mulligan previews his conference panel, “Lessons From the Front Line,” describing Harvey-era preparation and rescue execution, political and resource-prioritization challenges, the unexpected arrival of the Cajun Navy, and an EMS-related “tug-of-war” over a resource that drove extended after-action discussions. He explains that before Harvey, the department had limited high-water exposure, lacked boats and swift-water capability, and then added equipment and planning after prior floods while still maintaining normal EMS call volume during Harvey. Mulligan also discusses attending a broader disaster conference to learn how emergency response affects downstream mitigation and recovery. Resources: Connect with Chief Mulligan on LinkedIn Natural Disasters Expo USA Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo 2026 Speaker Series: Leading Through a Disaster: Dalton Rice on Lessons from Back-to-Back 1000-year Floods 30.09.2026 10min

  Welcome to Natural Disasters Expo Houston! For its fifth year, Natural Disasters Expo USA comes back to Houston on October 14–15, 2026, at the George R. Brown Convention Center. And there's no better place for it. This city knows what it takes to prepare for disasters, respond, and rebuild afterward. For two days, industry leaders, government agencies, first responders, and resilience professionals will come together with one shared goal: helping communities weather the next storm stronger than the last. Explore new solutions and technology, learn from experts who have been on the front lines, and meet the partners who will help you turn preparedness into action. Whether you're here to learn, share, or collaborate, you're part of the effort to build a more resilient nation. In this speaker series, Tom Fox interviews Dalton Rice, City Manager of Kerrville, ahead of the Natural Disaster Expo 2026, where Rice will speak on “Leading Through a Disaster: Hill Country Floods 2025.”  Rice previews a leadership-focused talk on how individuals and organizations navigate disasters, emphasizing immediate mental health support, burnout prevention, and adapting operations while continuing to run cities and departments. He plans to incorporate lessons from Kerrville’s July 4, 2025, flood and a second major flood on July 16, 2026, noting differences between fatality events and devastation-only disasters and how politics, resources, and pace of response affect outcomes. Rice says he values the conference for networking and building a “Rolodex” of peers, and he explains his goal of creating practical guidance for city managers, including challenges such as legislative dynamics, IT issues, hate mail, death threats, and separating disaster response from organizational operations. Key highlights: Dalton Rice Role and Background Talk Preview: Leading Disaster Back-to-Back Flood Lessons Resilience Mindset and Burnout Conference Goals: Networking Why Share Lessons Learned Resources: Dalton Rice Profile Natural Disasters Expo USA  Get your Ticket Conference Agenda Speakers 2026 Learn more about your ad choices. Visit megaphone.fm/adchoices
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  From Prosecutor to White Collar Lawyer to CCO and Back: Mike Koenig 28.09.2026 33min

  In this episode, Tom Fox welcomes Mike Koenig to talk about his career and his recent move back to private practice after a 5-year stint at JBS. Mike is one of the few folks to move from private practice to an in-house CCO role, then back to private practice. Mike began by reviewing his career, from 25 years in private practice and a 2003 DOJ Fraud Section stint prosecuting corporate fraud to becoming chief compliance officer at JBS in August 2021 amid DOJ and SEC settlement agreements requiring an effective compliance program. He describes learning to operate within business-driven priorities by building relationships, learning the business and culture, “educating not dictating,” and securing C-suite, board, and audit committee buy-in, including CEO-driven training completion. He explains that he uses trusted outside experts and focuses on the specific problem to solve rather than “boiling the ocean.” After JBS completed the settlements and listed on the NYSE in June 2025, he returned to private practice at Friedman Kaplan to advise on investigations and compliance, emphasizing concise, solution-oriented counsel. He warns against de-prioritizing compliance despite reduced enforcement, urges risk assessments (tariffs, export controls, and human rights), and recommends using DOJ compliance guidance to review programs. Key highlights: Career Journey Recap Joining JBS In-House Building Compliance Fast Relationships Not Dictates Leadership Buy-In FCPA Pause or a Wake-Up Call Compliance Through 2030 Resources: Mike Koenig on LinkedIn Mike Koenig at Friedman Kaplan Friedman Kaplan 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Natural Disaster Expo Houston: Preparedness, Resilience, and Business-to-Government Networking 18.09.2026 16min

  In this episode, Tom Fox welcomes Jack Moss, CEO & Board Member at Fortem International, to discuss the Natural Disaster Expo series and the upcoming Houston event (October 14–15). Moss explains the expo evolved from a UK Flood Expo launched about 10 years ago and expanded in the U.S. after interest from major agencies and stakeholders, including FEMA, Homeland Security, NASA, and NOAA, first in Miami and later California, then Houston as disasters increased in Texas. The conference brings together government entities, municipalities, first responders, private industry, risk and compliance professionals, reconstruction and construction providers, and funding-related participants to source products and services and learn how to predict, prevent, and manage disasters. Listeners can get a free pass to the event by using the link and code below. Key highlights: From UK to US Why Disaster Expo Expanding Across States Preparing for Disasters Resources: Natural Disaster Expo Click for Free Pass 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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  Michelle Tavares on Why Compliance Teams Need EB-5 on Their Radar 14.09.2026 25min

  In this episode, Tom Fox 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). Tavares explains EB-5 as an investor visa program where foreign nationals invest $1,000,000 (or $800,000 in a TEA) in U.S. projects that must create jobs, and she describes how EB-5 transactions sit at the intersection of immigration, securities, banking/AML, and corporate governance, making consistent documentation and a unified “story” critical for adjudication. She outlines the roles of regional centers, NCEs, and JCEs; the challenges of proving a lawful source of funds; and the importance of third-party oversight, KYC/AML controls, and tone-from-the-top governance. She discusses how RIA added compliance expectations, penalties, and increased scrutiny of regional centers and overseas promoters, and shares why she founded Standard & Proof Investigations to close knowledge gaps in EB-5 compliance. Key Highlights: EB-5 Basics and Why It Matters RIA Overhaul and New Compliance Inside the Adjudicator Mindset Boardroom Governance for EB-5 Third-Party Oversight Essentials 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. Learn more about your ad choices. Visit megaphone.fm/adchoices
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  9/11 Twenty-Five Years Later: Part 6: John Lee Dumas - “I Knew I Was Going to War” 11.09.2026 19min

  Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast series so that we never forget.  On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Today Tom’s guest is John Lee Dumas. John is the host of the award-winning podcast Entrepreneurs on Fire, joins Tom Fox on the last installment of Looking Back at 9/11 to commemorate the 20th anniversary of the 9/11 attack. He tells Tom how his life changed in that pivotal moment, and the big lessons he learned.  A Time of War John tells Tom that he was in his final year at Providence College, and in the ROTC cadets, on 9/11. When he saw the towers fall, he knew at once that it would change the trajectory of his career. He and his roommate looked at each other and they knew “that our next four years of active duty army experience went from being in the peacetime army to looking like we were going to war.” Within hours they were called to active duty: “We just became officers in the US army during a time of war,” John recalls. Leadership Lessons from the Army Tom asks John what leadership lessons he learned from his time in the army. John outlines three major takeaways that his time in combat taught him: To learn from those who went before. “I learned right at the beginning, I needed to stand upon the shoulders of giants,” he remarks. A good decision now is better than a great decision later. Action is everything. Make the best decision you can with the information you have, take action, then adjust if you need to when you know more. If you discover later on that you made a wrong decision, cut your losses and move on. Don’t compound that mistake by staying in a bad place, John advises. “I kept being willing to pull back and say let's try again, until I finally made a great decision. It took six years to make my first great decision, but that great decision has led to the last 10 years of living the exact life that I want to live.” What Americans Should Remember John wants Americans to appreciate their freedom, because it was hard won. He tells listeners, “So few people have ever experienced what true lawlessness is. And until you’ve experienced that, it's hard to really appreciate what we do have here. But you know, this is a great country and it is the home of the free because of the brave. And I hope that's just something that we will always remember.” Resources John Lee Dumas: ⁠Entrepreneurs on Fire⁠ | ⁠Twitter   Learn more about your ad choices. Visit megaphone.fm/adchoices
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  9/11 Twenty-Five Years Later: Part 5: Scott Moritz – It Changed Overnight 10.09.2026 23min

  Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget. On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Today, Tom’s guest is Scott Moritz for this episode of Looking Back at 9/11, where Scott talks about how the events of 9/11 impacted the FBI. ⁠How 9/11 Changed The FBI: Structural and Cultural Ambidexterity 9/11 fundamentally changed the FBI overnight. Scott remarks that for a long time after 9/11, the FBI was primarily focused on the attack on the Trade Center. That was the Bureau’s main investigation, and all FBI field offices and virtually every foreign attaché office in the world worked on it. Many scholars, through various organizational studies and surveys, assumed that the FBI would have created simultaneous frontline structures and processes to balance its two competing missions: national security and law enforcement. The scholars also posited that the FBI might engage in cultural ambidexterity by refusing to take on the national security mission altogether. The FBI did something altogether unexpected and tackled both.  The Benefit of One Agency “There was this rapid emergence of two clear, but distinct, identities, and eventually, you know, one new unified identity: the FBI, but some changes were that terrorism cases were centralized at headquarters…This was a big departure from the way that the FBI normally operated,” Scott tells Tom. By staying a single agency, the FBI had better access to local law enforcement and could better leverage defendants for information that could advance the national security mission. A Shift in the Private Sector Tom asks Scott to talk about any changes in the private sector he was personally involved in. The major post-9/11 change in the private sector, especially for financial institutions, was the enactment of the Patriot Act, which also paved the way for other significant changes. Financial Institutions and broker-dealers had to harden the security of buildings and supply chains across the country’s infrastructure. There was also an explosion of no-fly lists, watch lists, and terrorist watch lists. Banks, building owners, and brokerage companies often had to navigate these systems quickly. Scott was heavily involved in helping these institutions meet their anti-money-laundering and security obligations.  Looking to the Future Tom asks Scott to share reflections on 9/11 and the future. Scott remarks that after 9/11, the country was more united and people were more compassionate toward one another. The best of humanity in the form of kindness and outpouring of love was seen not just from Americans to each other, but from the rest of the world to America. He hopes he can see that kind of love and unity again someday.  Resources: Scott Moritz | ⁠LinkedIn⁠ ⁠Fraud Eats Strategy Front Office Agents Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices
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  9/11 Twenty-Five Years Later: Part 4: Eric Feldman – A Wake Up Call 09.09.2026 17min

  Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget. On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Today Tom’s guest is Eric Feldman. Eric is the Senior Vice President and Managing Director at Affiliated Monitors, a company that monitors large and small companies in government contracting, construction, engineering, manufacturing, and financial services. He also assesses corporate ethics and compliance programs across many countries. Eric joins Tom to discuss how the events of 9/11 changed the role of the Inspector General. The Impact of 9/11 on the IG’s Role Eric tells Tom that 9/11 was the most informative time of his career and of many other Inspector General’s. It was a moment of refocusing for everyone. Eric worked within the oversight function, but as part of the mission he was overseeing. “That focus on mission was it for me,” he tells Tom. Eric expresses that understanding the mission helped make him a better Inspector General. IGs worldwide became more concerned with the broader picture of how funds were used at their agencies to fight the war on terror, rather than the minutiae of time-and-attendance reporting. The Importance of the IG Now Tom asks Eric to elaborate on how the IG’s role rose in prominence post-9/11. Eric explains that government IGs became “part of the team” in different ways. There is more collaboration now across the agencies that IGs oversee. There is also independence: Eric expresses that there must be a balance between collaboration and independence. IGs are especially important because they ensure the dollars spent on the war and mission are spent properly. A Wake-Up Call of Unity Eric reflects that 9/11 was a wake-up call for the United States. The country came together, and unity, patriotism, and a sense of duty overtook politics. Eric hopes that the people can return to that unity without another catastrophe.  Resources: Eric Feldman | ⁠LinkedIn⁠ | ⁠Twitter⁠ ⁠Affiliated Monitors Learn more about your ad choices. Visit megaphone.fm/adchoices
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  9/11 Twenty-Five Years Later: Part 3: Alex Dill – Patriot Act: The AML Response to Terrorist Threats 08.09.2026 19min

  Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget. On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Today Tom’s guest is Alex Dill. Alex is a scholar and professor specializing in financial regulation, risk management, and compliance. He also has corporate experience in ​the ethics of business practices in finance, bankruptcy, bond covenants, and debt markets. He joins Tom to discuss the Patriot Act’s impact on responding to terrorist threats. How 9/11 Changed AML Before 9/11, AML regulations were very lax and backward-looking. The focus was on prosecuting crimes already committed and on money laundering more than on terrorist financing. Banks weren’t doing meaningful customer due diligence because they felt the process was invasive. After 9/11, this all changed. Law enforcement agencies and financial institutions revamped their policies and procedures to take a more preventive approach to AML and terrorist financing. This led to the Patriot Act. The Financial Response Tom asks Alex whether he saw a similar regulatory response among non-financial institutions regarding Patriot Act AML procedures post-9/11. “There was a huge amount of rulemaking that had to be done,” Alex responds. He adds that public companies adopted customer due diligence and applied it more broadly across sectors, using a risk-based approach. Companies now had to file suspicious activity reports, not just banks. Customer identification was also introduced. “The Patriot Act sought to encourage cooperation among law enforcement agencies and among the financial institutions themselves to share information and obtain information from foreign law enforcement authorities,” Alex tells Tom. The Challenge With The Patriot Act  Alex explains to Tom that the Patriot Act has challenges. A major challenge is detecting the financing behind these attacks. Funds that finance these actions come from both legal and illegal sources, and that is a major issue. Transaction amounts can be small, which may pose a risk for some compliance officers.  Technology in Anti-Terrorism Alex remarks that technology is very important in the fight against terrorism, as it has changed how we function in our world. The downside is that technology has also helped create some of the compliance issues we face today. Social media platforms have helped to create polarization in society, and criminals have used programs like cryptocurrency for money laundering and financing terrorism. However, Alex ends on a positive note, saying the AML Act of 2020 has been helping curb these issues. Resources: Alex Dill | ⁠LinkedIn⁠ | ⁠Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices
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  9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds 07.09.2026 18min

  Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget.  On the 20th anniversary of the 9/11 terrorist attack, Tom Fox and guests look back on the tragic event and what it meant for them personally, as well as how it impacted the world of compliance. Juan Zarate is the Global co-Managing Partner and Chief Strategy Officer at K2 integrity. On 9/11 he was a prosecutor at the Treasury Department working on international enforcement issues, anti money laundering, anti-corruption and anti-terrorist financing. He joins Tom Fox to commemorate the 20th anniversary of 9/11. They discuss how his role changed, the Treasury Department response and what the tragic event means for him. A Change of Mission 9/11 changed the mission of the Treasury Department. Juan tells Tom, “We went after terrorist financing to try to disrupt and dismantle Al-Qaeda's terrorist networks and infrastructure, and disrupt how illicit financing was flowing through the international system.” He recalls where he was on the fateful day and how seeing the smoke from the Towers and the Pentagon affected him emotionally. Something very different was happening, he recalls; the country was under attack. He outlines the strategic, departmental and tactical changes implemented after 9/11 to fight terrorism. The President declared that we were now at war. “The attitude and the strategic direction of the government was [that] we now have to prevent terrorist attacks,” Juan recalls. “We have to disrupt and dismantle terrorist networks. And that led to an entire preventative paradigm for the counter-terrorism approach to the government.” The new mission of the Treasury Department was the following areas, Juan remarks: “How do you use financial information more aggressively? How do we think about the use of tools and authorities that the Treasury has, like sanctions, anti money laundering rules? How do we think about the relationships internationally with central banks, finance ministries? How do we get the world on board to disrupt terrorist financing, to rip these organizations out of the legitimate financial commercial world?” The Patriot Act was one tactical change, among others, that was implemented to achieve the new mission of fighting terrorism. What 9/11 Means Tom asks Juan, “What are your reflections now as we come up on the 20th anniversary of the day of 9/11, and really what it meant for America and for you 20 years later?” Juan responds that he has mixed emotions. He thinks about the victims and their families first of all. That day changed history, he says. “It changed the way that the U S government viewed the world. It changed the way that we operated our strategy. And it changed the sense of our vulnerability.” The recent events in Afghanistan make the 20th anniversary even more difficult for Juan. “I have very mixed emotions coming on the 20th anniversary of 9/11,” he concludes, “but I'm very proud of the work that we did. I'm proud of the people I served with and my sympathies go out to the victims and their families.” Resources Juan Zarate at ⁠K2 Integrity⁠    Learn more about your ad choices. Visit megaphone.fm/adchoices