Tom Fox explores the recent case of JPMorgan Chase when an employee’s former manager added material to a terminated employee’s file post termination to beef up the excuses for the termination. Not a good sign, says Fox, and possibly a sign of an ineffective compliance program.
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
Next in line for regulatory troubles, Fiat?
Fiat, which was recently flagged by the EPA for pollution violations, could be a reminder to companies to scour the news for details on any regulatory investigations of their peers and perhaps to begin scrutinizing their own books and records, says The Man From FCPA Tom Fox.
Posted inRegulatory Enforcement
On the death of the ‘rogue engineer’
For The Man from FCPA Tom Fox, the most interesting thing about the Volkswagen indictments were not that ‘rogue engineers’ were charged but that executives who participated in the cover-up were indicted.
Posted inRegulatory Enforcement
Banks and bankers on front line of AML fight
The first foreigner, Jens Sturzenegger, a former branch manager at Falcon Private Bank in Singapore, was recently convicted in the 1MDB scandal. Tom Fox reports.
Posted inRegulatory Enforcement
Second VW exec arrested: those pesky e-mails
As the recent arrest of another VW executive (this time in the United States) unfolds, The Man From FCPA Tom Fox ponders whether VW will actively assist U.S. law enforcement authorities in performing a substantive internal investigation.
Posted inFrom the Archive
The Odebrecht enforcement action—the aftershocks
Have you been doing business with corruption-plagued Odebrecht? Better conduct a thorough internal investigation to ascertain if there are any red flags indicating suspicious payments, writes Tom Fox.
Posted inFrom the Archive
Technology, compliance, and the breakdown of corporate silos
The Man From FCPA Tom Fox explores the recent Foreign Corrupt Practices Act enforcement action involving General Cable Corp. and its implications for a technology-driven compliance world.
Posted inFrom the Archive
Michael Lewis’ ‘The Undoing Project’ and compliance
The Man From FCPA Tom Fox offers his take on the most recent Michael Lewis book, “The Undoing Project, A Friendship That Changed Our Minds,” which—Fox says—“should be studied by every compliance professional for its insights into how the human mind works.”
Posted inFrom the Archive
What is a paper compliance program?
In the recent Teva Pharmaceuticals FCPA enforcement action, the SEC Complaint laid out one of the best descriptions of a paper compliance program I have recently seen. To set the stage, the company had been made aware of illegal payments in its Mexico subsidiary, investigated the allegations and then fired several employees involved. The next […]
Posted inFrom the Archive
Odebrecht-US leads a massive global corruption settlement
The Odebrecht and Braskem global corruption settlements portend a new level of international cooperation in both investigation and enforcement.