Sometimes it does not take active bribery or corruption by an individual to violate anti-corruption laws such as the Foreign Corrupt Practices Act. It is one of the few laws which makes illegal consciously avoiding the actual knowledge of the underlying crime.
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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FIFA Internal Investigation: Between Scylla and Charybdis
Image: In theory, U.S. and Swiss authorities are working in tandem to investigate allegations of misconduct by the leaders of the FIFA professional soccer organization. In practice … relations are a bit more complicated, and that leaves the law firm handling FIFA’s internal probe in a difficult spot. CW anti-corruption blogger Tom Fox has more.
Conflicts of Interest in Track & Field: Perception or Reality?
Image: FIFA and NFL football are not the only sports mired in ethical controversy any more; now track and field has entered the race. The latest scandals include allegations of rampant doping among Russian athletes, and a clear conflict of interest from the new director of the sport’s oversight body. Our Man From FCPA, Tom Fox, has more.
First British DPA Provides Much to Ponder
It has finally come to pass: the first deferred-prosecution agreement under the U.K. Bribery Act. From the role of judicial oversight (greater than that in the United States) to the final statement of facts (much greater than that in the United States), the settlement with ICBC Standard Bank is full of lessons for compliance officers to weigh. Inside, our columnist Tom Fox works through the DPA and starts the pondering. More inside.
The Press and Exposure of Corruption: BAT Is Next
Allegations of bribery can come to light in many ways, but one way not usually mentioned—that was prominently featured last week—is through news reports. This time the media outlet was the BBC, and the allegations were that bribery at British American Tobacco Co. had occurred in violation of the Bribery Act. Our Man From FCPA, Tom Fox, reviews what was exposed and the potential consequences for BAT.
First DPA Under U.K. Bribery Act
Image: On Monday the U.K. Serious Fraud Office announced its first deferred-prosecution agreement under the Bribery Act for bribes ICBC Standard Bank Plc paid to government officials in Tanzania intended to sway their favor toward a proposed $600 million private placement. Inside, our anti-corruption blogger Tom Fox explores what lessons U.S. compliance officers might glean from the sanction.
Checking Up on GSK in China
When thinking through an FCPA risk assessment, one thing usually not considered adequately is a company’s sales culture. To see the consequences of that, one need look no further than GSK’s corruption troubles in China—but, CW blogger Tom Fox writes, the reforms GSK has implemented with its sales force are just as telling, too. Our Man From FCPA has more inside.
Should the FCPA Apply to International Sports Agencies?
Image: What’s happening with the intersection of sports and corruption? It seems as if several pillars of the international sporting world have come crashing down in the past few months through corruption scandals. Yet the FCPA usually does not apply in these corruption cases. Why? Tom Fox, our man from FCPA, has more inside.
FIFA as ‘Victim’: Your Response Matters When U.S. Government Pays Visit
Image: One lesson from the FIFA corruption scandal is that when the U.S. government comes knocking, it requires a serious and thoughtful response. So far, now-suspended FIFA president Sepp Blatter (left) has responded in a way decidedly not serious and thoughtful. Our anti-corruption blogger Tom Fox takes a closer look at how companies should behave when U.S. authorities visit, whether the company likes it or not. More inside.
Marrying Compliance Culture to Compliance Behavior
Image: A study by the Cranfield School of Management has identified five key concepts for companies to employ toward effective risk management. In a nutshell: anticipate problems; have adequate resources; flow information to the board; respond quickly to any incidents; and learn from the past. CW’s Tom Fox has more inside.


