It is incumbent that boards seek out and obtain sufficient information to fulfill their legal obligations and keep their company off the front page of the New York Times, Wall Street Journal, or Financial Times, just to name a few, to prevent serious reputational damage. A board compliance committee is a good place to start.
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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Compliance on the board
The Man From FCPA reveals what expertise is needed on the board of directors when your company is evaluated under the factors set out in Prong Three of the FCPA Pilot Program and the Evaluation of Corporate Compliance Programs.
Email Sweeps as continuous monitoring
Monitor, audit, and respond quickly to allegations of misconduct—these are the three components enforcement officials look for when determining whether companies maintain adequate oversight of their compliance programs.
FIFA trial and FCPA implications
From the requirements for an anonymous jury to the talk of “bag men” to the bandying about of some of the top names in sports broadcasting, the FIFA trials happeneing in New York City are proving to be a fascinating case.
Corruption and Saudi Arabia
There is a reason that Transparency International ranked the Kingdom of Saudi Arabia at 62 of the 176 countries listed in its most recent Corruption Perceptions Index: The open secret is that to do business in Saudi Arabia, bribes have to be paid.
The Yates Memo is alive and well
Even if the Justice Department revises and clarifies the Yates Memo, the substance of what Sally Yates was communicating is alive and kicking.
SEC makes an example of Alere
A recent enforcement action against a medical manufacturer for revenue recognition failures and bribery illustrates some interesting new enforcement trends for the SEC.
Individual prosecution in Rolls Royce corrupt case
For those who might have wondered if the Jeff Sessions’ Justice Department was going to enforce the Foreign Corrupt Practices Act, that question seems to have been answered in the affirmative.
Compliance and unethical business practices down the chain
The fallout from the KPMG and McKinsey scandals in South Africa has led to backlash from customers—including Barclay’s and Munich Re—demonstrating not only the potential reputational harm for engaging in unethical business practices, but the real risk for losing business opportunities.


