Image: 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 remediate—is it that easy? CW’s FCPA blogger Tom Fox explores further 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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Jumping on the VW Amnesty Microbus
Image: Last week Volkswagen offered amnesty to employees who admit any role they played in the emissions-testing scandal currently wracking the company—no 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: 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 company’s 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.
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.
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.
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.
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 […]


