All articles by Tom Fox – Page 10
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How character relates to compliance
Merely having in place a paper compliance program does not account for the human condition, which unfortunately is not always pure of heart, writes The Man From FCPA, while considering a recent book, “The Character Gap,” by Christian Miller.
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More fallout from Och-Ziff corruption case
In an interesting turn of events, the Och-Ziff corruption case recently reared its head once again, following news that Michael Cohen—who once oversaw the company’s investments in Europe, the Middle East and Asia—is facing criminal charges of fraud and obstruction of justice, according to recently unsealed court documents.
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The stunning Petrobras securities lawsuit settlement
In a stunning capitulation, Petrobras settled with U.S. investors for nearly $3bn in a class-action lawsuit as follow-on litigation to the long-standing corruption allegations against the company.
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Ruling against PwC may portend greater auditor scrutiny
A court ruling in a lawsuit brought by the Federal Deposit Insurance Corporation against PwC for its failure to detect a multibillion-dollar fraud may well portend greater skepticism and scrutiny by auditors when looking at FCPA issues.
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The role of global payroll in compliance
When it comes to following the money and staying in accordance with Department of Justice regulations, global payroll is the most well-suited corporate discipline to provide first-level oversight and controls.
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CCO authority and independence
The more the Justice Department talks about CCO independence, coupled with resources being made available and authority concomitant with the CCO position, the more corporations will see it is in their best interest to provide the resources, authority, and gravitas to compliance positions within their organizations.
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What newspapers do you read?
In this day and age, it would be wise for chief compliance officers to keep on top of the news, especially when it regards corruption, says The Man From FCPA.
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Compliance and employment separation
Before beginning any layoffs, it is essential that the compliance practitioner work with the legal department and HR function to make certain employment separation documents are in compliance with SEC rules.
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The imperial CEO
Former GE CEO Jeff Immelt managed in a way that he could have a backup private jet follow him around, but never had time to speak with the person managing the fleet...or to let the Board know about his infamous "ghost plane."
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Where is your backup?
A power outage at Atlanta’s Hartsfield Airport is a reminder to us all that having backup systems in place is essential to good business.
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The desktop risk assessment
If you perform an annual Desktop Risk Assessment with a full worldwide risk assessment every two years, you should be in a good position to keep abreast of compliance issues that may change and need more or greater risk management.
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What is risk?
Reports indicate the world’s largest cement manufacturer, LafargeHolcim is under investigation relating to its former operations in Syria.
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Putting a human face on the internal reporting process
Some lessons from two infamous whistleblowers: Daniel Ellsberg, who was responsible for the Pentagon Papers, and Wendy Addison, who spoke recently about her experiences in bringing to light fraud and corruption in LeisureNet Ltd. back in 2000.
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Is the FIFA brand toxic?
FIFA continues to present lessons for the compliance practitioner, and this one is straight-forward: if your organization is corrupt, other companies may well not want to do business with you going forward.
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Compliance in an economic downturn
In an economic downturn, there are two increasing compliance risks for companies that could make them in conflict with the 2012 FCPA enforcement guidance: (1) They eliminate compliance personnel in a cost-cutting attempt; (2) They neglect to invest monies needed to enhance monitoring or other mechanisms.
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Mapping your internal compliance controls
By mapping out the internal controls your company has in place to the indicia of the FCPA Enforcement Guidance’s Ten Hallmarks of an Effective Compliance Program and the 2013 COSO Internal Controls Framework, your company can ascertain what it has and what needs to be implemented.
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Aggressive global anti-fraud enforcement to continue
If you thought that enforcement actions like Odebrecht and Vimpelcom were behind us, guess again. They were just the tip of the iceberg. Welcome to the enforcement era.
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Uber seriously needs some compliance
After all of the misfirings at Uber this year, the company needs to appoint a chief compliance officer, who reports directly to the CEO, and works to change the values while putting in the infrastructure to support the backbone of a best practices compliance program. Sooner, rather than later.
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To operationalize compliance, pick up the phone
Following compliance policies and procedures is always important but to have a live person to answer questions or walk a non-compliance person through the process is a must.
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Fighting the economic cost of corruption
The U.S. Justice Department’s new FCPA enforcement policy seems to suggest that it’s in the best interests of the United States to both keep the playing field level for American companies and help raise the level of economic growth through fighting bribery and corruption across the globe.