The joint Department of Justice and Securities and Exchange Commission 2012 FCPA Guidance came out five years ago this month. All compliance practitioners should thank the government regulators and prosecutors who had a part in drafting this most remarkable of documents.
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 inUncategorized
Staying home to avoid justice?
“Honey, I think we should stay at home for Christmas this year.” This is the line that may well have been said by Marco Polo Del Nero, the president of the Brazilian Soccer Federation to his wife, after having been indicted on money laundering charges, but not subject to extradition to the United States.
Posted inAnti-Bribery
Saudi corruption crackdown—uncharted waters in the desert
What does the corruption crackdown in Saudi Arabia mean for investors? Is it positive for the Kingdom of Saudi Arabia in terms of investment dollars? Should investors run toward the Kingdom now or should they shy their investment dollars away? These and many other questions are being debated now. Both sides have their advocates and at this point, it is not clear who has the better argument.
Posted inBoards & Shareholders
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.
Posted inBoards & Shareholders
Board of directors’ compliance committee
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.
Posted inUncategorized
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.
Posted inAnti-Bribery
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.
Posted inAnti-Bribery
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.
Posted inUncategorized
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.
