Does the recent FinCEN enforcement action against Thomas Haider, Moneygram’s CCO, portend a shift in Justice Department enforcement strategies?
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 inAnti-Bribery
When corruption is endemic and structural
The recent scandals involving JBS, Odebrecht, and Petrobras seem to imply that once Brazilian politicians go on the take, they stay on the take. Time for Brazil to update its anti-corruption regulations.
Posted inRegulatory Enforcement
Under FCPA investigation? Reconsider travel to the U.S.
The arrest of VW’s former top emissions compliance manager, Oliver Schmidt, who was departing the United States after a Christmas holiday and was thrown in jail and denied bail, will make it less likely for foreign countries to send their citizens to face U.S. justice.
Posted inInternal Controls
How Rome and Athens inform today’s company
The differences in roles between a corporate legal department and a corporate compliance function are akin to the differences between Rome and Athens.
Posted inAnti-Bribery
The case for robust FCPA enforcement
Two recent corruption scandals emanating from Brazil highlight the direct impact corruption can have on U.S. citizens and serve as telltale examples of why a robust FCPA enforcement regime is in the interest of the United States.
Posted inRegulatory Enforcement
CW 2017 event reveals few have read Justice Dept. Evaluation Guidance
A small percentage of the audience at Compliance Week 2017 had read the Justice Department guidance on evaluations. What are they missing, and why the delay?
Posted inRegulatory Enforcement
A Futurist on compliance
At Compliance Week 2017, Futurist Dr. Brian David Johnson started the show with his talk about artificial intelligence, the future of the compliance profession, and the position of the chief compliance officer.
Posted inRegulatory Enforcement
Boards, compliance, and ongoing strategy
Board members must learn to take a more active role to not only prevent scandals—but when they do arise, ask tough questions of management and the compliance function about what is being done to remediate the situation.
Posted inRegulatory Enforcement
How do you determine judgment at the CEO level?
In the case of Barclays CEO Jes Staley, judgment seems to be lacking, as the executive first attempted to unmask an anonymous internal whistleblower and now has intervened in a Brazilian private-equity deal involving his brother-in-law.
Posted inAnti-Bribery
The intersection of corruption and the environment
Petrobras is attempting to sell a petrochemical plant that is “notorious for its multiple accidents, fires, and emissions releases,” according to reports. At issue? No environmentally responsible company would be interested in the doomed facility.