All articles by Tom Fox – Page 12
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The (anti) corruption London bus tour
A London bus tour that features the proceeds of corruption, exploring properties alleged to have been purchased with monies purloined from the country of Nigeria by the country’s former oil minister, the disgraced and now arrested, Diezani Alison-Madueke.
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Design of your compliance training
The Man From FCPA identifies what steps companies should take after giving employees a risk ranking to design effective compliance training.
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Risk-ranking and compliance training
The Justice Department’s Evaluation of Corporate Compliance Programs advises taking a risk-based approach to identifying employees in the three-tiered ranking.
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Does a compliance department need a behaviorist?
Tom Fox offers some detailed steps to help companies upgrade and improve their corporate compliance programs.
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Compliance lessons from the World Series
How does baseball correlate to compliance? The Man From FCPA explores where the two meet in terms of data analytics, strategic risk, and discipline.
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Lesson from Alere enforcement action
The Man From FCPA explores the recent Alere Foreign Corrupt Practices Act enforcement action and the lessons brought forth.
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Creating a culture of data in compliance
How can a chief compliance officer work to improve the company’s use of data to ensure the effective use of such an important asset? Tom Fox explores below.
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Revising your code of conduct
See inside for some tips based on the Justice Department’s Evaluation of Corporate Compliance Programs for help revising your Code of Conduct,
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Baseball informs your compliance program
With the Houston Astros set to play in the 2017 World Series, the Man From FCPA is tuning in and—much to his surprise—learning that baseball has multiple lessons for the compliance professional.
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Culture, compliance, and the board
Companies need to beware of two debilitating types of corporate culture, according to Uber board member Arianna Huffington, “the cult of the top performer” and “the culture of burnout and stress.”
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Harvey Weinstein—the FCPA angle
More trouble for Harvey Weinstein? The scandal-plagued Hollywood exec’s purchase of a $75K dress that was given to an un-named Qatari individual who was prepared to invest some $20,000,000 in an animation movie fund could be an FCPA violation.
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Post-acquisition integration under the FCPA
Companies should make sure they do three things in the M&A context, post-acquisition to ensure they don’t become entangled in an FCPA violation while attempting to expand.
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Pre-acquisition due diligence in mergers and acquisitions
This list of pre-aquisition due diligence tasks in the face of mergers will help companies thwart legal and business risks to reputation and profitability.
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What is your investigation protocol?
When viewing compliance as a clear series of steps leading to an effective goal, CCOs should take into account Hallmark 8 in the Ten Hallmarks of an Effective Compliance Program as supplemented by information from the Justice Department in its Evaluation of Corporate Compliance Programs.
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Continuous improvement through ongoing monitoring
Your compliance program should use ongoing monitoring to both evaluate and improve your regime going forward. And, writes Tom Fox, don't forget to: document, document, document.
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What is high risk for your brand?
The fraudulent certification scandal that rocked Japanese steel manufacturer Kobe Steel serves as a warning to other companies: Make sure your front-line employees feel like they can speak up in the face of fraudulent behavior.
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Germans arrest VW executive
Will the recent arrest of VW former Chief Engineer Wolfgang Harz mean more prosecutions of those involved in the worldwide cover-up of the emissions testing scandal? Tom Fox has more.
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Is a country sweep coming to South Africa?
The recent corruption scandal to focus on McKinsey & Co., SAP, and KMPG in South Africa has driven home a truism that many in the compliance space have known for some time: South Africa is one of the most corrupt countries on earth. For U.S. and U.K. companies doing business ...
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Recovering from an ethical scandal
How does a company restore its reputation after an ethical failure? Tom Fox explores how KPMG will react after its faulty audits of the embattled Gupta family.
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Lessons from the Telia FCPA resolution
The largest FCPA resolution on record (so far), at nearly $1 billion, offers plenty of objective lessons for compliance practitioners looking to better understand enforcement trends.