Over the years, there has been a siren’s call for the addition of a compliance defense to the FCPA. It’s time to send the so-called “compliance defense” packing.
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
South Africa sets up corruption commission
The Man From FCPA explores South African President Jacob Zuma’s intent to set up a nationwide corruption commission to look into allegations of rampant corruption through looting of government agencies and state-owned entities.
Posted inFrom the Archive
Compliance and the immigration debate
The raids by ICE last week on 7-Eleven stores nationwide portend a good reason to document, document, document, and The Man From FCPA suggests you go back and double check your documentation at both your corporate headquarters and at each location, so if the government comes raiding, you will be able to demonstrate compliance with the relevant immigration laws.
Posted inAccounting & Auditing
Wells Fargo still suffering financially from scandals
Wells Fargo is one of the poster children over what can happen when compliance is not taken seriously or perhaps not at all in an organization.
Posted inAnti-Bribery
What is your investigation protocol?
If you follow this basic protocol from The Man From FCPA, you should be able to work through most investigations, in a clear, concise and cost-effective manner.
Posted inAnti-Bribery
Non-monetary and indirect cost of a FCPA investigation
The Man From FCPA recently spoke with Dan Chapman, CEO of Presyse Compliance, about his experience with the non-monetary costs and indirect costs of a major FCPA investigations.
Posted inFrom the Archive
Oh thank heaven?
Tom Fox explores the recent raids by agents from the U.S. Immigration and Customs Enforcement (ICE) of 7-Eleven stores across the country, looking for undocumented workers from an FCPA perspective.
Posted inEthics & Culture
How character relates to compliance
Merely having in place a paper compliance program does not account for the human condition, which unfortunately is not always pure of heart, writes The Man From FCPA, while considering a recent book, “The Character Gap,” by Christian Miller.
Posted inUncategorized
The role of risk management in compliance
As compliance evolves and corporate compliance programs become more sophisticated, compliance is seen not as simply a legal prophylactic, but as a business process, writes The Man From FCPA.
Posted inUncategorized
The Fair Process Doctrine in compliance
Human resources has a key role to play in operationalizing the compliance program, specifically by ensuring that discipline is handed out fairly across the company and to those employees who integrate ethical and compliant behavior into their individual work practices, writes The Man From FCPA.
