Reports indicate the world’s largest cement manufacturer, LafargeHolcim is under investigation relating to its former operations in Syria.
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
Is the FIFA brand toxic?
FIFA continues to present lessons for the compliance practitioner, and this one is straight-forward: if your organization is corrupt, other companies may well not want to do business with you going forward.
Posted inRisk Management
Putting a human face on the internal reporting process
Some lessons from two infamous whistleblowers: Daniel Ellsberg, who was responsible for the Pentagon Papers, and Wendy Addison, who spoke recently about her experiences in bringing to light fraud and corruption in LeisureNet Ltd. back in 2000.
Posted inAnti-Bribery
Compliance in an economic downturn
In an economic downturn, there are two increasing compliance risks for companies that could make them in conflict with the 2012 FCPA enforcement guidance: (1) They eliminate compliance personnel in a cost-cutting attempt; (2) They neglect to invest monies needed to enhance monitoring or other mechanisms.
Posted inInternal Controls
Mapping your internal compliance controls
By mapping out the internal controls your company has in place to the indicia of the FCPA Enforcement Guidance’s Ten Hallmarks of an Effective Compliance Program and the 2013 COSO Internal Controls Framework, your company can ascertain what it has and what needs to be implemented.
Posted inAnti-Bribery
Aggressive global anti-fraud enforcement to continue
If you thought that enforcement actions like Odebrecht and Vimpelcom were behind us, guess again. They were just the tip of the iceberg. Welcome to the enforcement era.
Posted inEthics & Culture
Uber seriously needs some compliance
After all of the misfirings at Uber this year, the company needs to appoint a chief compliance officer, who reports directly to the CEO, and works to change the values while putting in the infrastructure to support the backbone of a best practices compliance program. Sooner, rather than later.
Posted inAnti-Bribery
To operationalize compliance, pick up the phone
Following compliance policies and procedures is always important but to have a live person to answer questions or walk a non-compliance person through the process is a must.
Posted inAnti-Bribery
The Holy Grail of compliance
A recent academic paper discusses companies’ progress in having the “Holy Grail of compliance,” the ability to demonstrate a positive return on investment (ROI) for your compliance program.
Posted inAnti-Bribery
Best practices under the new FCPA Enforcement Policy
The Justice Department’s new Foreign Corrupt Practices Act Corporate Enforcement Policy once again makes the importance of a best practices compliance program even more critical.
