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The Man From FCPA

The Man From FCPA is a blog about enforcement of the Foreign Corrupt Practices Act and other anti-bribery statutes around the world, written primarily by Compliance Week columnist Tom Fox plus other occasional contributors. Fox is now an independent consultant assisting companies with FCPA and compliance issues, after many years as in-house counsel and outside counsel on anti-bribery and corruption issues. Fox also hosts a weekly podcast, “The FCPA Compliance and Ethics Report,” and writes an in-depth monthly column for Compliance Week as well.
26 results found, filtered by:
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The Man From FCPA Blog
What is a business relationship?
Tom Fox | July 25, 2018
The Man From FCPA ponders the FCPA considerations of electric-car company Tesla putting the squeeze on its suppliers by asking them to refund monies Tesla had paid to them, as far back as 2016.
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The Man From FCPA Blog
FIFA sends a letter
Tom Fox | January 30, 2018
Under the FCPA there must be more than simple communication of instructions to not engage in bribery and corruption. Yet, FIFA only wagged its finger and said “do not engage.” Makes one wonder if the organization is actually ready to change.
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The Man From FCPA Blog
First step to end the Car Wash investigation?
Tom Fox | July 17, 2017
The will to continue the fight against institutional corruption in Brazil may be waning. From the perspective of The Man From FCPA, it appears that it is the beginning of the end for the seismic change that has come over the country starting with Operation Car Wash.
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The Man From FCPA Blog
FCPA enforcement-giving confidence to financial markets
Tom Fox | July 3, 2017
Judge Stanley Sporkin’s foresight in enacting the Foreign Corrupt Practices Act in the correct manner is a big reason behind why there is a large amount of confidence in U.S. companies.
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The Man From FCPA Blog
FIFA fires its own investigators
Tom Fox | May 10, 2017
When it comes to brassiness, one really cannot do much better than FIFA. After having survived one of the world's greatest scandals, the international governing body of football is replacing the leadership of its ethics committee, in effect dismissing the judge and the prosecutor whose investigations resulted in the suspensions of those parties involved in the corruption.
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The Man From FCPA Blog
Uganda—a demand side response to corruption
Tom Fox | May 3, 2017
A look at corruption in Uganda and the government’s fear that the high level of corruption is making life worse for citizens and driving out foreign investment.
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The Man From FCPA Blog
New foundation to protect sports whistleblowers
Tom Fox | March 19, 2017
A venture capitalist, a former United States federal prosecutor, and an Olympic gold medalist have formed a non-profit foundation, Fair Sport, to help mitigate risk for whistleblowers in the wide, wide world of sports.
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The Man From FCPA Blog
The Samsung corruption scandal—an unrecognized cost
Tom Fox | February 27, 2017
The past year was particularly bad for Korean electronics giant Samsung, and it looks like 2017 has gotten off to the same rough start. Tom Fox looks at the recent arrest of Lee Jae-yong, vice chairman of Samsung Electronics, on charges of bribery, embezzlement, and perjury.
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The Man From FCPA Blog
Spain and the fight against royal corruption
Tom Fox | February 21, 2017
A guilty verdict that sent the brother-in-law of the King of Spain to jail for fraud could signal that Spain is getting serious about corruption. Tom Fox says it was the first time a member of the Spanish royal family had been forced to stand trial, a move widely applauded by the Spanish public.
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The Man From FCPA Blog
The Fourth Estate and the fight against corruption
Tom Fox | February 13, 2017
‘When one plank of the fight against bribery and corruption’ falters, the media steps in. Tom Fox looks at the press’s role in fighting crime.
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The Man From FCPA Blog
Why bribery is bad for business
Tom Fox | February 13, 2017
The Man From FCPA Tom Fox explores what happens when a company’s foundation is shaky and illegal.
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The Man From FCPA Blog
Romanians take a stand against corruption
Tom Fox | February 11, 2017
What does the Romanian people's revolt against igovernment's proposal to decriminalize bribery and corruption within the country mean on a larger scale? The Man From FCPA Tom Fox says they have earned the right to say to Washington: “the whole world is watching.”
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The Man From FCPA Blog
Tales of crocodile tails under the FCPA
Tom Fox | October 25, 2016
While the FCPA makes clear it prohibits providing anything of value to a foreign governmental official, who’s to say what has value? For U.S. officials, it could be jewelery, cash, or sports tickets. But for Chinese executives, it could be something more exotic, say ... crocodile meat? Tom Fox has more on what value means under the regulation.
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The Man From FCPA Blog
Corruption becomes a political issue in Mexico
Tom Fox | October 25, 2016
Tom Fox looks at Mexico’s struggle to turn itself around, beginning with a political discussion and the introduction of FCPA-like anti-corruption regulation. Is it a turning point or a false start?
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The Man From FCPA Blog
Perception, reality, and global anti-corruption enforcement
Tom Fox | September 7, 2016
Tom Fox looks at scandals involving Swedish business empire Industrivärden and Apple that point to an increasing need for good compliance programs in an age of corruption and social media.
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The Man From FCPA Blog
FCPA compliance and the social contract
Tom Fox | August 4, 2016
Tom Fox looks at how Foreign Corrupt Practices Act compliance promotes multiple corporate stakeholders.
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The Man From FCPA Blog
Don’t put illegal conduct in power point slide presentations
Tom Fox | May 2, 2016
“Death by PowerPoint” is a typical description of really poor presentation technique, but it might just be a way to describe how some companies accidentally self-report their own corruption. Tom Fox has more.
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The Man From FCPA Blog
New Justice Department guidance and FCPA Pilot Program
Tom Fox | April 15, 2016
When the DoJ speaks, chief compliance officers should listen—especially when the talks center on enforcement. The agency has launched a pilot program for Foreign Corrupt Practices Act enforcement that details three areas of self-disclosure to be required by companies going forward. If a company meets all three areas, it could look forward to a 50 percent discount toward penalties. Tom Fox has full disclosure inside.
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The Man From FCPA Blog
Will Olympus see FCPA trouble in China?
Tom Fox | April 13, 2016
Trouble seems to follow Japan-based Olympus. The company, which admitted in 2011 to a $1.7 billion accounting fraud, is once again facing corruption allegations. Olympus hired China-based Anyuanto to help turn it around, despite the fact that Anyuan’s chairman had previously been convicted of fraud; Olympus’ contract wasn’t with Anyuan directly; and Olympus made $180,000 in payments upfront for “unspecified services.” So far an internal probe has turned up nothing interesting. We’ll have to wait to see what regulators uncover.
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The Man From FCPA Blog
Brazilian corruption investigation goes supernova
Tom Fox | April 1, 2016
As billionaire construction magnate Marcelo Odebrecht prepares to turn state’s evidence in the corruption investigation that covers Petrobras, Odebrecht SA, and the Brazilian presidency itself, it seems that we might finally get some insight on just how pervasive Brazil’s so-called “cartel of corruption” really was. Is anybody ready to handle the truth?
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The Man From FCPA Blog
The Greek Culture of Corruption
Tom Fox | February 10, 2016
Envelopes stuffed with cash and entire industries poised to take action against the first sign of whistleblowing are just two of the hallmarks of the endemic corruption that bedevils the entire Greek economy. What can be done when compliance isn’t just absent in a country, but actively avoided as a matter of tradition?
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The Man From FCPA Blog
Some Costs of Corruption
Tom Fox | December 30, 2015
A recent Financial Times article says that non-U.S. corruption scandals have outpaced those which are U.S.-centric and, FT points out, the companies at the heart of these scandals fared pretty badly from their own transgressions. Inside, FCPA blogger Tom Fox examines the cases of Volkswagen, whose emissions fraud has caused the company’s share price to drop more than 30 percent; iconic Japanese entity Toshiba’s $1.3 billion accounting scandal; and Swedish company Industrivärden, whose perquisite scandal has decimated the board of directors. All of this and no mention of FIFA. What will 2016 bring?
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The Man From FCPA Blog
Europe and Petrobras—What Has a Car Wash Wrought?
Tom Fox | November 4, 2015
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.
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The Man From FCPA Blog
The UN, Corruption, and Internal Investigations
Tom Fox | October 30, 2015
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.
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The Man From FCPA Blog
Naming and Shaming in FCPA Enforcement
Tom Fox | August 31, 2015
One thing that critics of the Foreign Corrupt Practices Act constantly flail is the (alleged) lack of individual prosecutions under the law. Perhaps naming and shaming individuals responsible for actual FCPA violations would get word to the business community to take anti-corruption more seriously.
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