After settling an FCPA enforcement brought by the SEC in March, Novartis is now under criminal investigation in South Korea for alleged illegal payments to physcians. Should the SEC reopen its investigation?
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 inData Privacy
EU Privacy Shield hits snag
Somehow, U.S. and EU officials find themselves with a Privacy Shield proposal that both goes too far, and yet, not far enough. The Man From FCPA Tom Fox has more.
Posted inAnti-Bribery
Unaoil-Can things get any bigger?
The Justice Department and SEC have their work cut out for them, says FCPA blogger Tom Fox, as the Monaco-based Unaoil scandal—in which the company used commissions to bribe clients—may be the biggest corruption enforcement action yet.
Posted inFrom the Archive
Theranos and compliance
One of the most compelling business stories over the past 18 months or so has been that of the Theranos, the developer of a perhaps revolutionary blood testing system, which allegedly allow testing of blood with such a small amount a person would only need their finger pricked. No longer would there be the need […]
Posted inAnti-Bribery
The other cleat drops in the FIFA corruption probe
Image: The FIFA corruption probe has shifted to U.S. corporations that did business with FIFA, regional soccer federations, and national soccer organizations, prompting some companies, including Nike, DirectTV, and Standard Chartered, to start their own internal investigations. The message is quite clear for those U.S. companies with affiliations to soccer regulators: You need to get out ahead of the government probe now by investigating any business dealings you might have had in this arena, says CW’s FCPA blogger Tom Fox.
Posted inEthics & Culture
What does the controversial pay raise for BP’s CEO mean for compliance?
Image: What are the implications of CEO pay during an economic downturn for your compliance program? In this piece, the Man From FCPA Tom Fox explores that question in the context of BP’s recent pay raise given to Bob Dudley, who, as CEO, laid off thousands of employees and saw a significant drop in share price.
Posted inAnti-Bribery
New Justice Department guidance and FCPA Pilot Program
When the DoJ speaks, chief compliance officers should listen—especially when the talks center on enforcement. The agency has launched a pilot program for Foreign Corrupt Practices Act enforcement that details three areas of self-disclosure to be required by companies going forward. If a company meets all three areas, it could look forward to a 50 percent discount toward penalties. Tom Fox has full disclosure inside.
Posted inAnti-Bribery
Will Olympus see FCPA trouble in China?
Trouble seems to follow Japan-based Olympus. The company, which admitted in 2011 to a $1.7 billion accounting fraud, is once again facing corruption allegations. Olympus hired China-based Anyuanto to help turn it around, despite the fact that Anyuan’s chairman had previously been convicted of fraud; Olympus’ contract wasn’t with Anyuan directly; and Olympus made $180,000 in payments upfront for “unspecified services.” So far an internal probe has turned up nothing interesting. We’ll have to wait to see what regulators uncover.
Posted inAnti-Bribery
The Butcher, the Baker and the Candlestick Maker … in Cuba, they are all covered under the FCPA
The winds of change are coming to Cuba, and U.S. businesses are slowly, but surely, beginning to get their long-awaited opportunities to set up shop in one of the world’s last truly socialist states. But this brings with it a most unusual FCPA liability that makes doing business in Cuba impossible without a really good compliance program. Tom Fox discusses.
Posted inAnti-Bribery
FCPA enforcement ramps up in Q1 2016
If it looks like FCPA enforcement is at a low ebb, judging by the amount of activity we saw in 2015, don’t be fooled. The SEC is prosecuting FCPA cases with vigor, and if some of the current enforcement actions underway are any indicator, we will not see a significant downturn of FCPA investigations any time soon. CW’s Tom Fox looks at the trend inside.