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.
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
The desktop risk assessment
If you perform an annual Desktop Risk Assessment with a full worldwide risk assessment every two years, you should be in a good position to keep abreast of compliance issues that may change and need more or greater risk management.
Posted inAnti-Bribery
Where is your backup?
A power outage at Atlanta’s Hartsfield Airport is a reminder to us all that having backup systems in place is essential to good business.
Posted inAnti-Bribery
What newspapers do you read?
In this day and age, it would be wise for chief compliance officers to keep on top of the news, especially when it regards corruption, says The Man From FCPA.
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 inEurope
What is risk?
Reports indicate the world’s largest cement manufacturer, LafargeHolcim is under investigation relating to its former operations in Syria.
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 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.
