Posted inBest Practices

From mainframes to Agentic AI, what legacy system discipline can teach us about building trustworthy customer data platforms

For the past decade, I’ve led customer data and regulatory platforms at one of the world’s largest card issuers, following years modernizing mainframe systems at IBM. The mainframes I maintained early in my career were not sophisticated by modern standards. They earned the trust of the organizations that depended on them anyway, because every transaction […]

Posted inBest Practices

China’s “Mythos moment” is coming. Its release gate is already built.

China’s “Mythos moment” is coming. Its release gate is already built. Washington spent June 2026 governing Mythos-level models for the first time: Systems whose autonomous cyber and agentic capabilities register as national security consequences. The label borrows from Anthropic’s Mythos 5, restricted that month; the government’s attention also reached OpenAI’s GPT-5.6. No Chinese lab has […]

Posted inBest Practices

When compliance reporting creates false assurance

Boards are not short of compliance information. Most receive dashboards, heat maps, training figures, investigation data, audit findings, remediation updates, and regulatory summaries. The difficulty is deciding what all that information really says. A report can be accurate, well presented, and still leave directors with too much confidence. That happens when evidence of activity is […]

Posted inSanctions

How ordinary Russian investors got caught in the sanctions net

When sanctions against Russia began multiplying in 2022, the public images were hard to miss: Yachts seized in European ports, villas frozen, bank accounts linked to oligarchs blocked. What I remember from the compliance side looked less visible and much more procedural. It was passports, residence permits, source-of-wealth documents, ownership charts, explanations of old bank […]

Posted inBest Practices

Navigating the supply chain’s new normal

A supply-chain disruption can look simple: A supplier cannot deliver, procurement finds an alternative, engineering qualifies it and production continues. Geopolitical disruption rarely arrives labeled as a compliance problem. It arrives as a sourcing decision, engineering fix or logistics reroute before compliance becomes involved. Recent developments include: Enforcement shows what can be at stake. In […]

Posted inBest Practices

Record-setting AML penalty against UBS was years in the making

FinCEN and several other regulators levied a combined $125 million penalty against UBS Financial Services (UBSFS), a broker-dealer and futures commission merchant, due to a series of long-standing compliance failures. The total penalty was a joint effort of federal regulators, including FINRA ($20 million), the Securities and Exchange Commission ($20 million), and the Commodity Futures Trading […]

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