A recent enforcement action against a medical manufacturer for revenue recognition failures and bribery illustrates some interesting new enforcement trends for the SEC.
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.
LinkedIn: Follow
Individual prosecution in Rolls Royce corrupt case
For those who might have wondered if the Jeff Sessionsโ 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 customersโincluding Barclayโs and Munich Reโdemonstrating not only the potential reputational harm for engaging in unethical business practices, but the real risk for losing business opportunities.
The (anti) corruption London bus tour
A London bus tour that features the proceeds of corruption, exploring properties alleged to have been purchased with monies purloined from the country of Nigeria by the countryโs former oil minister, the disgraced and now arrested, Diezani Alison-Madueke.
Design of your compliance training
The Man From FCPA identifies what steps companies should take after giving employees a risk ranking to design effective compliance training.
Risk-ranking and compliance training
The Justice Departmentโs Evaluation of Corporate Compliance Programs advises taking a risk-based approach to identifying employees in the three-tiered ranking.
Does a compliance department need a behaviorist?
Tom Fox offers some detailed steps to help companies upgrade and improve their corporate compliance programs.
Lesson from Alere enforcement action
The Man From FCPA explores the recent Alere Foreign Corrupt Practices Act enforcement action and the lessons brought forth.
Compliance lessons from the World Series
How does baseball correlate to compliance? The Man From FCPA explores where the two meet in terms of data analytics, strategic risk, and discipline.
Creating a culture of data in compliance
How can a chief compliance officer work to improve the companyโs use of data to ensure the effective use of such an important asset? Tom Fox explores below.


