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.
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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Empathy might be the secret ingredient your compliance program needs
Being a great compliance officer requires more than strong analytical skills and acumen. It requires soft skills like emotional intelligence, too, since compliance is ultimately all about people.
For ENI, business risk, geography, and political risk all come together
How does a company assess its risks and, more importantly, how does it manage them? That’s the question FCPA blogger Tom Fox hoped to answer recently when he explored the case of Italian energy company ENI’s focus on doing business in Africa—known for being politically risky—which put some investors ill at ease.
Bribery a plus for small business in South Korea?
Small businesses in South Korea object to new anti-corruption laws, claiming their implementation will hurt sales of luxury goods for bribes. Tom Fox explores further.
FCPA issues arise at Goldman trial in London
There is nothing quite like a trial to bring all kinds of information to light that various parties would rather keep out of view. Goldman Sachs is now learning that the hard way in a suit regarding Libya’s sovereign wealth fund that has some serious FCPA implications. Tom Fox reports.
A second corruption scandal arises in Brazil
Most of Brazil’s corruption focus over the past couple of years has been around Petrobras and the fallout from Operation Car Wash, but a second corruption scandal (dubbed Operation Zelotes) has arisen in Brazil that could be equally massive—this one relating to tax evasion by not only Brazilian companies, but also multinationals doing business in Brazil. Tom Fox has the details.
Quid pro quo and FCPA enforcement
The Supreme Court’s reversal of the public corruption conviction of former VA Governor McDonnell should not have any effect on FCPA enforcement going forward. Tom Fox has more.
When is contract price a risk?
Does a low bid contract present a compliance risk? Tom Fox examines what could go wrong now for Panama with the grand opening of the Panama Canal.
Compliance front and center
The SEC and Justice Department have made it clear that it will no longer be adequate for companies merely to have a compliance program in place; it must actually be taken seriously from within and given the power and resources to do its job. Tom Fox explores.
WADA and its non-response to whistleblowing
What are the implications of an entity not responding to allegations, which come to its attention through a whistleblower? In the FCPA world, such corporate behavior can lead to significant legal and financial consequences. The Man From FCPA was therefore intriged by recent reports that the World Anti-Doping Agency (WADA) had long ago received information […]


