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.
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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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, โThe Character Gap,โ by Christian Miller.
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.
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.
More fallout from Och-Ziff corruption case
In an interesting turn of events, the Och-Ziff corruption case recently reared its head once again, following news that Michael Cohenโwho once oversaw the companyโs investments in Europe, the Middle East and Asiaโis facing criminal charges of fraud and obstruction of justice, according to recently unsealed court documents.
The stunning Petrobras securities lawsuit settlement
In a stunning capitulation, Petrobras settled with U.S. investors for nearly $3bn in a class-action lawsuit as follow-on litigation to the long-standing corruption allegations against the company.
Ruling against PwC may portend greater auditor scrutiny
A court ruling in a lawsuit brought by the Federal Deposit Insurance Corporation against PwC for its failure to detect a multibillion-dollar fraud may well portend greater skepticism and scrutiny by auditors when looking at FCPA issues.
CCO authority and independence
The more the Justice Department talks about CCO independence, coupled with resources being made available and authority concomitant with the CCO position, the more corporations will see it is in their best interest to provide the resources, authority, and gravitas to compliance positions within their organizations.
The role of global payroll in compliance
When it comes to following the money and staying in accordance with Department of Justice regulations, global payroll is the most well-suited corporate discipline to provide first-level oversight and controls.
Compliance and employment separation
Before beginning any layoffs, it is essential that the compliance practitioner work with the legal department and HR function to make certain employment separation documents are in compliance with SEC rules.


