All articles by Tom Fox – Page 11
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The Holy Grail of compliance
A recent academic paper discusses companies’ progress in having the “Holy Grail of compliance,” the ability to demonstrate a positive return on investment (ROI) for your compliance program.
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Best practices under the new FCPA Enforcement Policy
The Justice Department’s new Foreign Corrupt Practices Act Corporate Enforcement Policy once again makes the importance of a best practices compliance program even more critical.
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For Uber: what else? Not: where else?
Another Uber reveal, this time the fact that the company make a $100K payment to hackers who broke and stole confidential data of some 57 million Uber customers and drivers, leaves many wondering what else the transportation company has kept in the dark.
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The compliance oversight committee
Installing a compliance oversight review committee is a crucial step that should be employed by companies as added protection against any type of compliance and ethics violations that could slip through the cracks and become much bigger problems down the road.
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The regional compliance committee
The regional compliance officer adds a dimension not often seen or even discussed in the compliance profession, offering oversight of the compliance monitoring, reviewing, assessing, and recommending that is deemed necessary to the compliance function.
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Doing business with Citgo? Get ready for a bumpy ride
The arrest of Citgo Petroleum Company’s acting president of the company and five members of the company’s board for offering bonds to finance the company’s continued operations means that if you’re doing business with Citgo, it’s definitely time to review your relationships, contracts, payment status, and all other facets of ...
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What does ‘Made in Japan’ stand for now?
Mitsubishi Materials knew for months one of its subsidiaries was shipping low-quality products, giving the phrase ‘Made in Japan’ a whole new meaning.
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Happy Birthday to the FCPA Guidance
The joint Department of Justice and Securities and Exchange Commission 2012 FCPA Guidance came out five years ago this month. All compliance practitioners should thank the government regulators and prosecutors who had a part in drafting this most remarkable of documents.
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Staying home to avoid justice?
“Honey, I think we should stay at home for Christmas this year.” This is the line that may well have been said by Marco Polo Del Nero, the president of the Brazilian Soccer Federation to his wife, after having been indicted on money laundering charges, but not subject to extradition ...
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Saudi corruption crackdown—uncharted waters in the desert
What does the corruption crackdown in Saudi Arabia mean for investors? Is it positive for the Kingdom of Saudi Arabia in terms of investment dollars? Should investors run toward the Kingdom now or should they shy their investment dollars away? These and many other questions are being debated now. Both ...
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Compliance on the board
The Man From FCPA reveals what expertise is needed on the board of directors when your company is evaluated under the factors set out in Prong Three of the FCPA Pilot Program and the Evaluation of Corporate Compliance Programs.
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Board of directors’ compliance committee
It is incumbent that boards seek out and obtain sufficient information to fulfill their legal obligations and keep their company off the front page of the New York Times, Wall Street Journal, or Financial Times, just to name a few, to prevent serious reputational damage. A board compliance committee is ...
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FIFA trial and FCPA implications
From the requirements for an anonymous jury to the talk of “bag men” to the bandying about of some of the top names in sports broadcasting, the FIFA trials happeneing in New York City are proving to be a fascinating case.
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Email Sweeps as continuous monitoring
Monitor, audit, and respond quickly to allegations of misconduct—these are the three components enforcement officials look for when determining whether companies maintain adequate oversight of their compliance programs.
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Corruption and Saudi Arabia
There is a reason that Transparency International ranked the Kingdom of Saudi Arabia at 62 of the 176 countries listed in its most recent Corruption Perceptions Index: The open secret is that to do business in Saudi Arabia, bribes have to be paid.
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The Yates Memo is alive and well
Even if the Justice Department revises and clarifies the Yates Memo, the substance of what Sally Yates was communicating is alive and kicking.
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SEC makes an example of Alere
A recent enforcement action against a medical manufacturer for revenue recognition failures and bribery illustrates some interesting new enforcement trends for the SEC.
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Individual prosecution in Rolls Royce corrupt case
For those who might have wondered if the Jeff Sessions’ Justice Department was going to enforce the Foreign Corrupt Practices Act, that question seems to have been answered in the affirmative.
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Compliance and unethical business practices down the chain
The fallout from the KPMG and McKinsey scandals in South Africa has led to backlash from customers—including Barclay’s and Munich Re—demonstrating not only the potential reputational harm for engaging in unethical business practices, but the real risk for losing business opportunities.