Compliance Perspectives

By Adam Turteltaub Business transformations can be times both of risk and opportunity for compliance programs. Employees, struggling to understand the changes around them and feeling stressed, may opt to do the wrong or at least ill-advised things. By the same token, transformations provide an opportunity for compliance teams to change their roles within the organization and redefine the value tha...

By Adam Turteltaub Oh, Artificial Intelligence. So much promise, and so much risk. What’s a compliance and ethics professional to do? Start by listening to this podcast about the chapter “Managing the Ethics and Compliance Risks of Artificial Intelligence” in the 2025 edition of The Complete Compliance & Ethics Manual . We spoke with the article’s co-authors, Gwen Hassan (chief compliance offi...

By Adam Turteltaub Sometimes you make a few technical changes to a compliance program  because a law or regulation has changed. Autoliv didn’t want to do that and just meet technical requirement of the EU Whistleblower Directive . They wanted to use it as an opportunity to assess what they were doing to encourage employee reporting, whether it was working, and to improve support for people speakin...

By Adam Turteltaub So the IT folk can’t wait for your business people to delete those old documents, meantime, the business people want to hold onto them because they never know when they might need that info again. Then, all of a sudden there’s a legal issue and a hold is in place. Instantly the game changes. Chris Kruse , Executive Vice President & Advisor at CasePoint explains that when a l...

By Adam Turteltaub You do all that work but how do you know you’re being successful? It’s not like people come running in the door and say, “Hey, guess what bad thing I almost did.” The compliance team at the National Security Agency (NSA) had that same challenge. In this podcast, Natalie Knowles, Director of Compliance, and Zack Conyne, Manager, first provide an overview of the NSA. As they expla...

By Adam Turteltaub When we last spoke with Tyler Shultz back in 2020, he discussed his experience at Theranos as both an employee and a whistleblower. Four years later, the case is in the rearview mirror, the former CEO is in prison, he founded two startups of his own, and he now speaks to corporations about cultivating courageous work cultures With the benefit of some time and distance, he shares...

By Adam Turteltaub Few things hold more promise, or cause more stress for compliance professionals, than AI. What is it?  How does it work? And does anyone know how to keep it from showing so much bias? David Silva , Chief Compliance Officer at Collaborative Imaging, will be addressing the topic of “Healthcare, Artificial Intelligence, and Compliance” at the 2025 HCCA Compliance Institute , which...

By Adam Turteltaub Chart auditing may not be the sexiest part of healthcare compliance, but it plays an important role in discouraging Medicare fraud and catching problems early. Madhavi Perumpalath , Director-Physician Practice Compliance at Northeast Georgia Health System and Alka Kumar , Compliance Director and Privacy Officer at Resolve Pain Solutions, explain that CMS provides good guidance t...

By Adam Turteltaub With value-based care growing, what role does compliance play?  To find out we spoke with Carolyn Barton , Vice President, West Regional Compliance Officer at Kaiser Permanente. She explains that at Kaiser they define value-based care as a healthcare delivery and financing model that improves health outcome and increases access to affordable care in the community through evidenc...

By Adam Turteltaub No one would dispute that stress and compliance go hand in hand, but Scot Eibel ( LinkedIn ), a former chief compliance officer and currently leading Eibel Coaching and Compliance Consulting , warns that doesn’t mean it has to get out of control. There are steps we can all take to manage our stress levels. One stressor to watch for is over vigilance.  While we all need to be vig...

By Adam Turteltaub Benjamin Christenson, Trial Attorney and Special Assistant to the Director for Criminal Enforcement at the US Department of Justice Antitrust Division, joins us for this podcast in which he sheds light on the their document, Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (ECCP). First issued in 2019, the ECCP was updated in 2024 to reflect chang...

By Adam Turteltaub Want to improve your code of conduct? Don’t miss the session: Cornering the Code: A Multi-Disciplinary Approach Toward a Better Code of Ethics at the 2025 SCCE European Compliance &  Ethics Institute . In this podcast Matej Drascek , Head of Internal Audit at LON d.d. and Ursula Schmidt of Schmidt Advisory recommend starting with the right language. Research has shown, they...

By Adam Turteltaub I want to write enough about this podcast to get you to listen to it, but not too much because then you might decide that reading this was enough. I’m conflicted, and conflicts of interest are the topic of this podcast with Kasturi Venkatesh , who spoke on the topic “Ethics in Action: A Fun Guide to Tackling Personal Conflicts of Interest” at the 2024 SCCE Compliance & Ethic...

By Adam Turteltaub On November 6, 2024, the U.K.’s Home Office issued  Economic Crime and Corporate Transparency Act 2023: Guidance to organisations on the offence of failure to prevent fraud (the Guidance). It comes out of the   Economic Crime and Corporate Transparency Act (ECCTA), which establishes that a corporation can be held criminally liable for failing to prevent fraud committed by...

By Adam Turteltaub Auditing and monitoring of the compliance program is pretty standard these days.  Entain’s Karen Nightingale , Group Director of Ethics & Compliance and Jonathan Fox , Group Head of Ethics & Compliance Programmes , make the case in this podcast for going to the next level and actively testing your program. The two will also be addressing the topic at the 2025 SCCE Europe...

By Adam Turteltaub Note:  This podcast was recorded on December 17, 2024.  Any changes made after this date will be addressed at the Compliance Institute. At the 2025 HCCA Compliance Institute in Las Vegas, Adam Greene ( LinkedIn ), partner at Davis Wright Tremaine LLP will be leading the session “New Developments in Health information Privacy.” In this podcast he provides an overview of what he s...

By Adam Turteltaub Well, it turns out that you can be in two places at once, if you are a surgeon. Even better, you can bill the government under the Medicare program for being at both of them. It’s not quite as strange as it sounds, explains Sara Brinkmann , Partner, and Lauren Gennett , Counsel, of King & Spalding, and, of course, there are rules. Overlapping surgeries occur when one attendi...

By Adam Turteltaub On November 22, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand what this all means, we spoke with Daniel Kahn  ( LinkedIn ) , partner at Davis Polk, and himself a veteran of the DOJ. There were a number of meaningful changes du...

By Adam Turteltaub Once again it is time to sit down with Matt Kelly  ( LinkedIn ), Editor and CEO at  Radical Compliance and discuss what happened last year and where the compliance profession is going in the new one. In this podcast we looked back at 2024 and explored five key topics. Changes from the DOJ The DOJ recently issued a recap of its key activities over the last year or so, and Matt no...

By Adam Turteltaub Retaliation is the bane of every compliance program, with the potential of destroying employee confidence in reporting systems, not to mention embarrassing and expensive lawsuits. It is also complex and can be subtle, explains Keith Read, a former chief ethics and compliance officer and author of the book  The Unconventional Compliance Officer: Doing Things Differently . There i...

By Adam Turteltaub How do you know your compliance program is working, both for your peace of mind or if the government comes knocking? It’s a tough question, and many wonder either how to start measuring or if they’re measuring the right thing. Andrew McBride , Founder & Chief Executive Officer at Integrity Bridge , has a great deal of experience in this area from his time serving as Chief Co...

By Adam Turteltaub Oh, come on, we all know it: sometimes the business people get tired of all those compliance requirements. That’s okay and to be expected.  But, how do you know when it has progressed beyond the usual (and maybe healthy) resistance to full-blown exhaustion? Cecilia Fellouse , General Manager of Compliance for Good, warns that, ironically, when the business team stops pushing bac...

By Adam Turteltaub Do you ever ask yourself, “What kind of compliance officer am I?” Netherlands-based  Susan du Becker , Director, Risk & Compliance at Microsoft, thinks we all should. To her experience, there are two answers to that question. One is a regulatory compliance officer: someone who is focused on the requirements of regulators, potential fines and legal consequence. The other is a...

By Adam Turteltaub Rob Tull ( LinkedIn ), Managing Director at Effective Compliance LLC wants every compliance officer to be both competent and able to demonstrate it. He advocates for the development of four sequential, underlying skills: Communication The ability to be aware of risks Adaptability, and Decision-making/judgement Underlying all of them is knowledge, and together they form a framewo...

By Adam Turteltaub Who are you talking to? When you think about all the employees in your organization, who do you see in your mind? You probably, and should, think of several people: the person in the plant, the R&D people, the sales team. They all have different needs, maybe even different cultures. Adam Balfour , Carsten Tams  and Karen Moore ( LinkedIn ), each of whom is a veteran complian...