All articles by Tom Fox – Page 12
-
Blog
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.
-
Blog
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 ...
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
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.
-
Blog
Does a compliance department need a behaviorist?
Tom Fox offers some detailed steps to help companies upgrade and improve their corporate compliance programs.
-
Blog
Lesson from Alere enforcement action
The Man From FCPA explores the recent Alere Foreign Corrupt Practices Act enforcement action and the lessons brought forth.
-
Blog
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.
-
Blog
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,
-
Blog
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.
-
Blog
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.
-
Blog
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.”