Tom Fox

Image: It appears the Fédération Internationale de Football Association is trying to shed its corrupt image in favor of playing the victim. The international governing body of football has asked the Justice Department for its share of monies it obtains through forfeiture and penalties from individuals prosecuted around the FIFA corruption scandal. But has the entity put any work into cleaning up its own house before seeking help? FCPA blogger Tom Fox explores.

The recent $101M heist from the Central Bank of Bangladesh would have been impossible had it not occurred over a weekend, and had weekends themselves not been observed on different days of the week in Bangladesh than they are in the United States. One thing’s for sure: Whenever the weekend happened, everybody was unhappy by Monday.

A 19-year prison sentence handed down in connection with Brazil’s widening “Car Wash” scandal is a wake-up call for any company that has done business with Odebrecht SA, the largest construction company in Brazil and, indeed, South America. The scandal, which began with energy firm Petrobras, should enforce that it’s time to begin reviewing the whole of your contractual relationships to see if there are any FCPA, U.K. Bribery Act, or other anti-corruption issues you need to address.

Image: The joint Justice Dept., SEC settlement with telecom giant VimpelCom resolving a longstanding FCPA violation will cost the company more than $795 million, say reports. But there’s a bright side, says CW Columnist Tom Fox. The multiple bribery schemes seem to have been supported by top management and will provide a wealth of case studies for companies hoping to avoid VimpelCom’s fate.

What is the cost of corruption? How much due diligence must you perform with those entities that are your customers? Does doing business with companies that have a propensity for corruption put your company at risk? In light of the scandals at Petrobras and Houston-based ENSCO, companies might want to consider if they have the right answers.

When corruption-plagued Brazilian energy giant Petrobras overpaid for a Houston-area refinery by some $950 million, it raised more than a few eyebrows. And when that refinery suffered a large explosion and fire recently, it showed that failure to practice good safety and failure to practice good business ethics go hand-in-hand.

Financial services providers face unique corruption risks when seeking to win business in international markets. This includes a traditional form of back-scratching: the hiring of children or other close family members of prominent foreign officials. Only now the SEC has made it clear that such practices can and will invite FCPA scrutiny.

As FIFA continues to battle its landmark corruption scandal, it has elected a new President and passed a series of structural and process reforms to bring the organization into the 21st century and demonstrate to U.S. authorities that it really is going to change from its prior culture. But is it enough?