At the annual Compliance Week conference, U.S. Justice Department and Securities and Exchange Commission representatives spoke about what constitutes an effective compliance program under the Foreign Corrupt Practices Act and the increased importance of an independent chief compliance officer. Our Man From FCPA Tom Fox explores further.
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
CCOs facing greater personal scrutiny from regulators
The Man from FCPA, Tom Fox, examines the recent FINRA disciplinary action against Raymond James CCO Linda Busby, in light of what appears to be broadening personal liability for chief compliance officers when it comes to FCPA enforcement.
Posted inAnti-Bribery
Is FIFA headed in the right direction?
Do FIFA’s latest governance moves an indicator of a genuine effort to reform this embattled organization? Or is it just shuffling the deck chairs? The Man From FCPA Tom Fox reports.
Posted inBoards & Shareholders
Of power and responsibility
With great power comes great responsibility. The Norwegian Oil Fund already knows that, but it appears the company will give the entire world a responsiblity lesson as it takes more interest in the corporate governance policies of those firms in which it invests. The Man From FCPA Tom Fox has more.
Posted inAnti-Bribery
The Yates Memo and the new normal for individual enforcement
In a speech before the New York bar, Justice Department Deputy Assistant Sally Yates detailed some of the effects the Justice Department has already seen from the Yates Memo, released last September, including a larger focus on individual actor culpability and a drive by DoJ lawyers to identify the individuals involved. The Man From FCPA reports.
Posted inAnti-Bribery
A blizzard of corruption has 2016 off to a roaring FCPA start
There has been enough foreign corruption turmoil in the first few months of 2016 that one almost doesn’t want to see what the rest of the year has in store. It’s the kind of year where, already, the Petrobras and Dieselgate scandals seem like a century ago. Tom Fox reports.
Posted inAnti-Bribery
New legal liabilities after Panama Papers?
The Man From FCPA, Tom Fox, looks at the implications behind the United Kingdom’s new mandate that banks selling to offshore companies in “murky territories” will be held responsible if it facilitates tax evasion by wealthy individuals, and how that mandate relates to anti-corruption compliance.
Posted inRegulatory Enforcement
A step toward the light of transparency, but only a small step
The U.S. government is now requiring banks to obtain the identifies of those they do business with—a rule, notes Tom Fox, that is long overdue. But criticism of the rule could point to a greater need for legislation to streamline the current system around the creation of corporations. Will Congress step up to the plate?
Posted inFrom the Archive
Deutsche Bank and the continuing costs of money laundering risks
Deutsche Bank demonstrates that the costs of continuing to fail to meet regulatory requirements regarding anti-money laundering can be astronomical. Tom Fox looks at the Financial Conduct Authority’s Deutsche Bank investigation and what it means for the financial firm’s future.
Posted inAnti-Bribery
Don’t put illegal conduct in power point slide presentations
“Death by PowerPoint” is a typical description of really poor presentation technique, but it might just be a way to describe how some companies accidentally self-report their own corruption. Tom Fox has more.