A significant source of funding or loan guarantees for VW may have become impaired, making the emissions-testing scandal and the attendant penalty phase potentially even more damaging for the automaker.
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 inRegulatory Enforcement
How Hui Chen prompted an evolution in compliance at the DoJ
Hui Chen’s time as compliance counsel at the DoJ’s Fraud Section was short and eventful and did a lot to move the needle on how the DoJ views corporate compliance programs.
Posted inRegulatory Enforcement
Compliance, risk, and the opioid scandal
The pharmaceutical industry may be the next victim of the opioid epidemic, as the government turns its focus on the pharmaceutical manufacturers themselves, not the addict or drug abuser.
Posted inInternal Controls
New twist in the Volkswagen investigation
In one of the more interesting and recent twists to the emissions-cheating scandal, Volkswagen has accused a group of fellow German car manufacturers of collusion over the diesel engine scandal, now almost two years old.
Posted inData Privacy
Wells Fargo and its data privacy faux pas
Wells Fargo continues to be in the news these days (and not for the better) in the way of its reputation.
Posted inRegulatory Enforcement
Change in prosecutorial strategy in VW case?
The recent arrest of an italian citizen in Germany, a former VW employee, may mean the government intends to bring charges against lower-level employees in an attempt to get them to flip on senior employees who were involved in the fraud.
Posted inAnti-Bribery
First step to end the Car Wash investigation?
The will to continue the fight against institutional corruption in Brazil may be waning. From the perspective of The Man From FCPA, it appears that it is the beginning of the end for the seismic change that has come over the country starting with Operation Car Wash.
Posted inRegulatory Enforcement
Once again, no judicial review of DPAs
While there will be no official review, a recent case where a federal district court approved a limited release of a Monitor’s report from the financial institution HSBC will have an impact on the court’s treatment of DPAs.
Posted inAnti-Bribery
FCPA Pilot Program leads to two 2017 declinations
The FCPA Pilot Program declinations we have seen so far in 2017 both make substantial additions to the precedent for how to avoid prosecution under the FCPA.
Posted inRegulatory Enforcement
Shell companies in the U.S.—beginning of the end?
The Man From FCPA explores the issues surrounding shell companies and, in particular, money laundering enforcement.
