Compliance officers should always remember there is a bribe receiver in a corruption case. That is why it is important to know not only your third party, but also with whom you are doing business.
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 inUncategorized
Using investigative findings as the basis of remediation
There is nothing like an internal whistleblower report about an FCPA violation to trigger the board of directors and senior management attention to the compliance function and the compliance program.
Posted inUncategorized
Compliance tone at the bottom
Even with a great tone-at-the-top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the “tone at the bottom.”
Posted inEthics & Culture
What is a conflict of interest?
A look at the case of Dr. Brenda Fitzgerald, the now former head of the Center for Disease Control, who invested in tobacco stocks after she became director.
Posted inUncategorized
FIFA sends a letter
Under the FCPA there must be more than simple communication of instructions to not engage in bribery and corruption. Yet, FIFA only wagged its finger and said “do not engage.” Makes one wonder if the organization is actually ready to change.
Posted inAnti-Bribery
South Africa reminds the FCPA covers political parties
For any company doing business in South Africa, all your contacts with the African National Congress have FCPA implications; This means all the investigations you might be performing for contracts with the South African government, anything associated with the Gupta family or state-owned enterprises, should be assessed for ANC contacts as well.
Posted inBoards & Shareholders
Why board oversight matters, in investing and compliance
The case of Outcome Health is a clear lesson for the anti-corruption compliance practitioner: Levels of oversight not only provide a backup to make sure that no mistake should slip through, but also the rigor of financial oversight.
Posted inAnti-Bribery
Tone in the middle of an organization
What should the tone in the middle be? This role is critical because the majority of company employees work most directly with middle, rather than top management and, consequently, they will take their cues from how middle management will respond to a situation.
Posted inAnti-Bribery
Financial incentives in a compliance program
You must be able to evolve in your thinking and professionalism as a compliance practitioner to recognize the opportunities to change and then adapt your incentive program to make the doing of compliance part of your company’s everyday business process.
Posted inEthics & Culture
The end of Japan Inc.?
What happens when a series of scandals so engulfs a country that its entire national brand is put in jeopardy? Japan may have the answer.
