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  • Michelle Tavares on Why Compliance Teams Need EB-5 on Their Radar

    Michelle Tavares on Why Compliance Teams Need EB-5 on Their Radar
    2026/09/14
    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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    26 分
  • 9/11 Twenty-Five Years Later: Part 6: John Lee Dumas - “I Knew I Was Going to War”

    9/11 Twenty-Five Years Later: Part 6: John Lee Dumas - “I Knew I Was Going to War”
    2026/09/11
    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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    19 分
  • 9/11 Twenty-Five Years Later: Part 5: Scott Moritz – It Changed Overnight

    9/11 Twenty-Five Years Later: Part 5: Scott Moritz – It Changed Overnight
    2026/09/10
    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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    23 分
  • 9/11 Twenty-Five Years Later: Part 4: Eric Feldman – A Wake Up Call

    9/11 Twenty-Five Years Later: Part 4: Eric Feldman – A Wake Up Call
    2026/09/09
    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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    17 分
  • 9/11 Twenty-Five Years Later: Part 3: Alex Dill – Patriot Act: The AML Response to Terrorist Threats

    9/11 Twenty-Five Years Later: Part 3: Alex Dill – Patriot Act: The AML Response to Terrorist Threats
    2026/09/08
    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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    20 分
  • 9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds

    9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds
    2026/09/07
    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
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    19 分
  • 9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo - Needing to Make a Difference

    9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo - Needing to Make a Difference
    2026/09/06
    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. Tom’s first guest this week is Gabe Hidalgo, anti money laundering compliance expert, who shares how the events of that fateful day changed the course of his career. Looking Back Gabe - who worked as outside counsel for insurance companies at the time - remembers turning on YahooTV as soon as he got to his office on 9/11 and seeing the second plane hit the World Trade Towers. He knew immediately that it was a deliberate attack. “I knew that this was kind of a hallmark moment,” he tells Tom, “that this was not an accident.” He details leaving the office in haste to get to his pregnant wife, and the obstacles and roadblocks he faced on the way. When they finally reunited at home, they were overcome with emotion. He remembers feeling gutted thinking about the unborn children who would grow up never knowing their fathers. Needing to Do Something Gabe needed to do something more than just shed tears about 9/11, he tells Tom. He started to think about how he could use his skills as an attorney. “I went down the path of looking in private industry, what I can do, and came across anti money laundering compliance, which I thought was fascinating. And I said to myself, I need a way for me to be able to get into that so that I can start making a difference.” He shares his journey into the field, and that it was exactly the right time and the right fit for him. 9/11 was a wake up call for America, he remarks. It made us realize that we need to do whatever we can to prevent anything similar from happening again. Evolution of AML Since 9/11 Tom asks Gabe how AML compliance has advanced since 9/11. It’s much more difficult for terrorist financiers to move funds now, he responds. “A lot of institutions have strengthened and hardened their compliance programs to the point where they can monitor individual transactions as they're moving across the transactional workflow in the United States. They examine each and every transaction that's coming across from a correspondent banking perspective, which is probably one of the most high-risk channels for money movement.” Gabe and his colleagues have done great work over the past 20 years, which has helped law enforcement stop and apprehend would-be terrorists. However, we can’t be complacent, Gabe says. Tom asks what 9/11 means for America. The 20th anniversary is a somber one, Gabe replies. 9/11 taught us not to be naive, that we’re not as protected as we think we are. He is proud of the advancements made to keep everyone safe, but the work continues. “It's a moment of reflection,” he points out. “We need to think about not only the people who have lost their lives, but everyone that was impacted - whether they were directly impacted through a family loss, or they were emotionally impacted by what actually occurred.” Resources Gabe Hidalgo on ⁠LinkedIn⁠ Learn more about your ad choices. Visit megaphone.fm/adchoices
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    21 分
  • Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance

    Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance
    2026/08/31
    In this episode, Tom Fox welcomes Mara Senn, founder and CEO of Ethakos, about her path from big law and a decade as a partner at Arnold & Porter to anti-corruption work at the Kleptocracy Initiative, investigations at the World Bank, and in-house leadership roles at Fortune 500 medical device and pharma companies. Senn explains she built the Ethakos compliance investigations platform using “vibe coding” with Claude, reducing reliance on software engineers and enabling rapid product decisions. She describes Ethakos as AI-native and human-in-the-loop, designed around how compliance teams actually work, with cleaner data creation, configurable workflows, and features that automate painful reporting tasks (e.g., investigation updates) and first drafts of chronologies, interview outlines, and reports. Senn emphasizes audibility via logs and citations, advises starting AI projects with clear risk goals, and predicts AI will remove menial work so teams can cover more risks while becoming more data- and tech-forward. Contact options include ethakos.com, email, and LinkedIn. Key highlights: Why Build Ethakos AI Native Platform Design Solving Reporting Pain Starting AI in Compliance Avoiding Common AI Mistakes Investigation Workflow Automation Auditability and Regulator Proofing Future of Compliance Teams Resources: Ethakos Mara Senn on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    31 分