A recent Foreign Corrupt Practices Act case found LATAM Airlines Group shouldering a heavy burden, paying out approximately $22.2 million in penalties. The significant costs, notes Tom Fox, seems to imply the Justice Department’s FCPA Pilot Program is working.
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 inFrom the Archive
AML due diligence for non-financial institutions: the next big thing in compliance?
What does the 1MDB scandal portend for non-financial companies and anti-money laundering compliance? Plenty, especially if they haven’t reviewed their AML policies and procedures in the last 12 months. Tom Fox reports.
Posted inAnti-Bribery
FCPA compliance and the social contract
Tom Fox looks at how Foreign Corrupt Practices Act compliance promotes multiple corporate stakeholders.
Posted inFrom the Archive
Why the U.S. must lead the global fight against corruption
As recent enforcement actions in Malaysia and Latin America have shown, the U.S. government must remain the world’s leader in the worldwide fight against the global scourge of corruption. Tom Fox has more.
Posted inRegulatory Enforcement
What states’ suit against VW means for corporate officer liability
New York, Maryland, and Massachusetts are claiming that top managers at VW were either specifically involved in the development and implementation of vehicle defeat devices, or knew of the issues that led to their creation. What does this mean for VW’s future—and, for that matter, what does it mean for chief compliance officer liability? Tom Fox has more.
Posted inFrom the Archive
Law firm involvement in the 1MDB Scandal
What does the use of the Shearman & Sterling trust account by 1MDB mean for the law firm?
Posted inAccounting & Auditing
Front-loading at HSBC
The woes at HSBC continue as executives in its forex unit face charges of trading manipulation. Tom Fox has more.
Posted inFrom the Archive
The Wolf of Wall Street comes to asset forfeiture
Plot twist! The Wolf of Wall Street, a movie about corruption on Wall Street, might have been funded by corrupt money. Suddenly, this is starting to sound more like Inception.
Posted inRegulatory Enforcement
Volkswagen channeled Lance Armstrong
How does Volkswagen’s conduct around its emission-testing scandal mirror the actions of Lance Armstrong? For one thing, both were involved in the largest scandals in their respective spheres: Armstrong in cycling, and Volkswagen in car manufacturing. Yet, the similarities go even further. Tom Fox reports.
Posted inAnti-Bribery
The new FCPA enforcement circle is now complete
A trio of recent Foreign Corrupt Practices Act enforcement actions shows just how much companies can spare themselves undue pain if they self-report violations early and without holding back. Tom Fox has more.
