Tom Fox explores the term “conscious avoidance” under the FCPA, specifically in the case of Frederick Bourke, who invested in an enterprise in Azerbaijan that was engaged in bribery and corruption to obtain certain oil and gas rights of which Bourke claimed he had no knowledge.
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 inEthics & Culture
Ethical questions from running
Tom Fox explores the case of new light-weight Nike footwear, scheduled to be released in June, which may violate standards set forth by the International Amateur Athletic Federation.
Posted inAnti-Bribery
Haiti Teleco—the sordid affair nears an end
The sordid 2011 Haitia Teleco matter may finally be winding down, as the last player was arrested in February for his involvement in payments of more than $1.4 billion to Haiti Telco representatives.
Posted inRegulatory Enforcement
Continued fallout at Wells Fargo leads to board scrutiny
The Wells Fargo fraudulent account scandal still resonates as one of the most prime examples where the continued fallout from a board’s failure in the area of oversight of risk management is working to damage the organization.
Posted inRegulatory Enforcement
Uber and corporate culture
Does a company have to behave ethically to succeed? Perhaps not, as the recent ethical failures of Uber suggest. The company could be in hot water over its Greyball program, designed to thwart sting operations intended to catch Uber violating any taxi terms of services regulations.
Posted inRegulatory Enforcement
German Chancellor questioned in VW scandal
What did German Chancellor Angela Merkel know and when did she know it? A German parliamentary investigation seeks to uncover the truth about how much Merkel knew about diesel emissions standards and the VW case.
Posted inRegulatory Enforcement
Oliver Schmidt—not quite Sgt. Schultz
“I see nothing! I hear nothing! I know nothing!” seems to be the rallying cry of former head of emissions compliance in the U.S. for Volkswagen Oliver Schmidt, who claims during the VW scandal, “he was a minor player misled by company lawyers and information technology specialists.”
Posted inAnti-Bribery
Companies now doing compliance in Brazil
Corporations in other countries are increasingly moving from a paper-based compliance program to actually doing compliance. The Man From FCPA Tom Fox reports.
Posted inAnti-Bribery
The Samsung corruption scandal—an unrecognized cost
The past year was particularly bad for Korean electronics giant Samsung, and it looks like 2017 has gotten off to the same rough start. Tom Fox looks at the recent arrest of Lee Jae-yong, vice chairman of Samsung Electronics, on charges of bribery, embezzlement, and perjury.
Posted inAnti-Bribery
Spain and the fight against royal corruption
A guilty verdict that sent the brother-in-law of the King of Spain to jail for fraud could signal that Spain is getting serious about corruption. Tom Fox says it was the first time a member of the Spanish royal family had been forced to stand trial, a move widely applauded by the Spanish public.
