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.
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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Law firm involvement in the 1MDB Scandal
What does the use of the Shearman & Sterling trust account by 1MDB mean for the law firm?
Front-loading at HSBC
The woes at HSBC continue as executives in its forex unit face charges of trading manipulation. Tom Fox has more.
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.
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.
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.
It is good to have friends at the top
It’s good to know someone at the top—that well-known maxim was demonstrated yet again recently when it was revealed that U.K. Chancellor of the Exchequer George Osborne intervened with the U.S. government during the investigation of money laundering violations by the U.K. bank HSBC. Tom Fox reports.
The chairman’s flight
The Justice Department has reached a plea agreement with David Sampson, the former chairman of the Port Authority of New York and New Jersey, who pressured executives of United Airlines to reopen a money-losing route, which flew near Sampson’s weekend home in South Carolina. In the world of the FCPA, says blogger Tom Fox, we rarely see a company CEO so directly involved in a bribery scheme. Fox has more.
Does compliance need a seat at VW’s table?
VW’s response to its defrauded customers in Europe is worse, than laughable. It’s indefensible. Where is the company’s compliance function? Tom Fox explores.
DoJ to everybody on FCPA prosecutions: We can make this all go away, you know
Just how serious is the Justice Dept. about making life easier if you comply fully with its FCPA violation investigations? Johnson Controls Inc. was caught dead to rights on egregious fraud—but, by cooperating with the DoJ, it managed to secure a declination to prosecute. Tom Fox reports.


