The bribery allegations against Shell and Italian energy company ENI makes one wonder: If monies paid to a foreign government itself are now subject to scrutiny, could it open up an entirely different exposure to liability for international organizations?
Tom Fox
Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in compliance through his best-selling book Upping Your Game. He has 38 other books on the use of AI in compliance and business ethics, leadership including the seminal work, The Compliance Handbook, with its 7th edition coming out in 2025. He is the founder of the award-winning Compliance Podcast Network.
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Posted inAnti-Bribery
Facilitation payments under the FCPA
In addition to its restrictions, a key to FCPA compliance is accurately recording facilitation payments going forward. As with all things FCPA-related, the “document, document, document” mantra holds.
Posted inAnti-Bribery
Extortion policies under the FCPA
An extortion payment, while not a violation of the FCPA, should have its own set of policies and procedures that employees adhere to per the chief compliance officer.
Posted inAnti-Bribery
Charitable entities and compliance
The stories of Plan International USA and of Oxfam make clear the need for robust compliance programs in a non-profit charity.
Posted inAnti-Bribery
Why is the U.S. government investigating GlaxoSmithKline now?
GlaxoSmithKline recently said U.S. enforcement agencies asked for information about third-party advisers the company hired in China during a corruption investigation in the country. The Man From FCPA asks, why now?
Posted inAnti-Bribery
The intersection of cyber-security with the compliance professional
New York’s Department of Financial Services (DFS) has issued the first state level regulations on cyber-security for financial institutions, but non-financial services industries should take heed of them as well.
Posted inBoards & Shareholders
Does your board have a compliance expert?
The Federal Reserve Bank this month assessed a penalty against Wells Fargo for the bank’s widespread customer abuse from its fraudulent accounts scandal, other regulatory violations, and lack of response by the bank’s doard of directors to these problems and other risk management issues.
Posted inUncategorized
Continuous monitoring to continuous improvement
To continuously improve a compliance program, the compliance team should apply a consistent set of protocols, checks, and controls tailored to the company’s risks. Tom Fox offers some guidance on how to do just that.
Posted inAnti-Bribery
The effects of corruption at home
Petrobras (of Operation Car Wash fame) will soon consider offers to sell a refinery located in Pasadena, bringing the effects of the FCPA home to the United States.
Posted inUncategorized
Deficiencies in ISO 37001
As the drumbeat of those supporting ISO 37001 continues, The Man From FCPA takes a look at the standard’s downside.
