A clear lesson to be learned from the Theranos scandal is when conducting merger due diligence, make sure to determine how a new partner conducts itself and its business.
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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Why HR compliance is critical to creating trust
The recent departure of Uber’s head of human resources suggests the company’s new speak-up cultural might not be all it’s cracked up to be.
Law firm files alleged evidence of bribery against former client
U.K.-based mining giant Eurasian Natural Resources Corp. is suing its former counsel and U.K. regulator the Serious Fraud Office for their complacency in leaking information about an investigation into the company for alleged bribery and corruption.
Will a Goldman partner flip?
The former head of Goldman Sachs southeast Asia is reportedly in discussions with the Justice Department and will likely plead guilty to federal charges regarding his involvement with the 1MDB corruption scandal. What will his involvement mean for the company, which continues to deny culpability?
What is the cost of a subpoena?
Glencore has seen a drop in its share price, which could be related to the Justice Department having issued a subpoena for possible FCPA violations in the Democratic Republic of Congo, Nigeria, and Venezuela.
Irony, FCPA enforcement actions, and M&A
Boeing’s planned acquisition of Brazilian company Embraer’s commercial jet business and LyondellBassell’s possible acquisition of Brazilian entity Braskem highlights an ironic twist to the FCPA: An enforcement action could be so financially draining that your company is forced to sell all or parts of itself, but results from that same action could actually make your company more attractive.
Hiring and the FCPA
The Credit Suisse FCPA enforcement action reminds us all again that it is not the hiring of family members or close friends of a foreign government official or employee of a state-owned enterprise that is illegal under the FCPA, only those hires made with corrupt intent.
Incorporating compliance into long-term corporate strategy
How can a board of directors work to incorporate the compliance function into a long-term business strategy of the organization? Tom Fox has a few ideas.
Payroll controls and compliance
How can payroll help when operationalizing a compliance program? Tom Fox explores payroll’s role and the four key areas that should be considered when reviewing compliance goals.
The continuing problem of shell companies
Businesses must conduct more robust background checks and must work to improve their internal controls around all third parties to make sure one does not slip through the corporate cracks and cause great damage.


