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 company’s compliance effort.
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 inAnti-Bribery
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.
Posted inAnti-Bribery
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.
Posted inAnti-Bribery
Europe and Petrobras—What Has a Car Wash Wrought?
Image: The scope of the Petrobras corruption scandal is literally worldwide. Now, reports the Financial Times, Rolls Royce has become embroiled in the Brazilian national energy company’s “Operation Car Wash” snafu (dubbed so because the investigation literally started with a car wash), and is currently under investigation by the British Serious Fraud Office for bribery. Now is the time for European chief compliance officers doing business in Brazil to learn from the scandal and, hopefully, come out ahead, says CW FCPA blogger Tom Fox. More of his thoughts inside.
Posted inAnti-Bribery
Bristol-Myers Squibb Dodges Criminal FCPA Enforcement
Image: Last week Bristol-Myers Squibb announced that the Justice Department has decided to prosecute the company for a criminal Foreign Corrupt Practices Act. When you look at the facts of the misconduct, a declination seems a bit far-fetched, but our Man From FCPA, Tom Fox, takes a closer look at the case and its teachable moments anyway.
Posted inAnti-Bribery
The UN, Corruption, and Internal Investigations
Image: Another corrupt scandal hit the United Nations recently. The claim was made that a former General Assembly president had engaged in receiving bribes and other corruption from a Chinese businessman (and perhaps others). Other than yet another embarrassment for the United Nations, the allegations are nothing unusual so far. What was was the response by the United Nations. The Man From FCPA, Tom Fox, has more.
Posted inAnti-Bribery
Compliance and the Zeitgeist in Germany
I have always been fascinated with the zeitgeist. In the world of anti-bribery and anti-corruption compliance, one rarely has the chance to observe the zeitgeist in action. However I think we are now seeing it play out in Germany in a public way. It all involves the Made in Germany brand, which I would have […]
Posted inRegulatory Enforcement
The Schrems Decision and Compliance
Image: While the recent Schrems decision has seen a signifcant focus on the lack of U.S. data privacy protection from government or company intrusion, CW’s FCPA blogger Tom Fox says the decision also raises issues with hotlines and internal investigations. With these two key components of any best practices compliance program seemingly unavailable to CCOs or compliance practitioners for EU-sourced information, Fox believes there will be additional pressure put on the compliance function. See more of his thoughts inside.
Posted inAnti-Bribery
Chinese Open New Front in Anti-Corruption Investigations
The Chinese fight against bribery and corruption took an interesting twist earlier this month, when it was announced that the former head of the national oil company, Sinopec, was being investigated for bribery and corruption in the securing of contracts in Angola. If this investigation continues it could open a new and very different phase of China’s fight against corruption. Details inside.
Posted inAnti-Bribery
FIFA Misconduct Strikes Again, at German Prestige
Image: The German magazine Der Spiegel is reporting that the committee set up by the German Soccer Federation to bid for the 2006 World Cup hosting rights ran a slush fund of more than 10 million Swiss francs ($11 million) to help secure those hosting rights. Given all that has occurred around FIFA recently, says CW’s anti-corruption blogger Tom Fox, this latest scandal signals a need for robust oversight going forward of the world’s most popular sporting organization. More inside.