When thinking through an FCPA risk assessment, one thing usually not considered adequately is a companyโs sales culture. To see the consequences of that, one need look no further than GSKโs corruption troubles in Chinaโbut, 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.
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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Should the FCPA Apply to International Sports Agencies?
Image:ย Whatโs 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 โVictimโ: Your Response Matters When U.S. Government Pays Visit
Image:ย 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:ย 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. CWโs Tom Fox has more inside.
Yates and Caldwell Lay Out Their FCPA Expectations
Image:ย Deputy Attorney General Sally Yates (left) and Assistant Attorney General Leslie Caldwell talked last week about what they, and more importantly the Justice Department overall, expect from companies that want to receive as much credit as possible when embroiled in a Foreign Corrupt Practices Act investigation. What companies should do: voluntarily self-disclose, fully cooperate, timely and appropriate remediateโis it that easy? CWโs FCPA blogger Tom Fox explores further inside.
Jumping on the VW Amnesty Microbus
Image:ย Last week Volkswagen offered amnesty to employees who admit any role they played in the emissions-testing scandal currently wracking the companyโno doubt drawing upon the success Siemens had when it made a similar offer to employees during a 2006 Foreign Corrupt Practices Act investigation. Opinions differ on the move, but many seem to agree that VW employees would be wise to jump on the Amnesty Microbus sooner, rather than later. Our Man From FCPA Tom Fox has more inside.
On Advertising and the FCPA
Image:ย When can advertising violate the FCPA? That might not be a question often on the minds of compliance officers. The ongoing FIFA corruption scandal, however, demonstrates that any expenditure going out of a corporation may well need to be considered from an anti-bribery angle. Tom Fox, our Man From FCPA, has more.
Justice Dept. Boosts Its Game for Corporate Compliance Programs
The Justice Department has long talked about the need for companies to take compliance programs seriously. Now with its first-ever compliance counsel hired (she started this month), the department itself will be able to bring a more practiced eye to evaluating compliance programs. This week, columnist Tom Fox reviews what we know about the compliance counsel and how her hiring may change Justice Department views on your companyโs compliance effort.
Leniency in Petrobras Scandal Means Decision on Self-Disclosure
As the Petrobras corruption scandal moves to the investigation of international companies that did business with the Brazilian national energy company, Europeans companies now face some challenging decisions around the issue of self disclosure. Our Man From FCPA, Tom Fox, has more inside about the considerations you need to make.
Yates Memo, D&O Coverage, and the Coverage Gap
One consequence of the Yates Memo that has not received as much attention is whether current directors-and-officers liability insurance provides appropriate insurance coverage for the legal expenses incurred by executives who might go through an internal investigation. The answer may well be no; Tom Fox has more inside.


