The Justice Department’s Evaluation of Corporate Compliance Programs advises taking a risk-based approach to identifying employees in the three-tiered ranking.
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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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 company’s use of data to ensure the effective use of such an important asset? Tom Fox explores below.
Revising your code of conduct
See inside for some tips based on the Justice Department’s Evaluation of Corporate Compliance Programs for help revising your Code of Conduct,
Baseball informs your compliance program
With the Houston Astros set to play in the 2017 World Series, the Man From FCPA is tuning in and—much to his surprise—learning that baseball has multiple lessons for the compliance professional.
Culture, compliance, and the board
Companies need to beware of two debilitating types of corporate culture, according to Uber board member Arianna Huffington, “the cult of the top performer” and “the culture of burnout and stress.”
Harvey Weinstein—the FCPA angle
More trouble for Harvey Weinstein? The scandal-plagued Hollywood exec’s purchase of a $75K dress that was given to an un-named Qatari individual who was prepared to invest some $20,000,000 in an animation movie fund could be an FCPA violation.
Post-acquisition integration under the FCPA
Companies should make sure they do three things in the M&A context, post-acquisition to ensure they don’t become entangled in an FCPA violation while attempting to expand.


