All articles by Tom Fox – Page 14
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Tone in an organization
Tom Fox explores the many levels of corporations and how they interact to create tone at the top, middle, and bottom.
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Structure of the CCO position
The Man From FCPA explores the three prisms by which the structure of the Chief Compliance Officer position can be evaluated: access, resources, and opportunities.
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What new headaches may befall FIFA?
A new and potentially very damaging turn has taken place in the ongoing FIFA corruption scandal. Miguel Maduro, former chairman of FIFA’s governance committee, said that if asked, he would provide specific accusations of top FIFA officials pressuring him to ignore regulations.
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Uber and “Hell”
The hits keep coming to beleaguered transportation firm Uber; reports have surfaced that an internal company program called “Hell” utilized software that allowed it to illegally interfere with Lyft, an Uber competitor.
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Remediation and the Equifax data breach
Equifax has a long road to travel to get past the recent data breach that saw 143 million people’s personal information exposed to theft.The company will need to engage in significant remedial action, notes The Man From FCPA, if they hope to survive the upcoming fallout.
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New scandals; new lexicon for unethical conduct
In the FCPA world, the most dreaded question during an enforcement action is “where else?”—as in, where else are you engaging in bribery and corruption? After Wells Fargo, the lexicon may well expand to “what else?”—as in what other conduct is your company engaging in that is unethical?
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Going weird in international bribery and corruption
As Hunter S. Thompson once said, “When the going gets weird, the weird turn pro.” Such is the case of BSG Resources after accusations surfaced that the company had paid bribes to obtain a huge mining concession in Guinea—charges it vehemently denies.
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For leniency, confess all crimes
The JBS meat-packing scandal is a perfect example of why companies must provide every single shred of evidence of criminal conduct, or a plea agreement might not be worth much.
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What are the effects of C-Suite involvement in bribery and corruption?
A look at the corruption cases of Samsung and Panalpina and the outcome from when C-Suite becomes involved in corporate bribery and corruption schemes.
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Preparing for compliance
One lsson learned from Hurricane Harvey applies to today’s compliance professional: You must do more than prepare for a compliance emergency by preparing beforehand, but you must also practice that preparedness.
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Will Uber change its toxic culture?
The Man From FCPA explores what the future has in store for Uber Technologies under new chief executive Dara Khosrowshahi.
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FCPA, CEOs and risk assessments
Ian Narev, chief executive officer of the Commonwealth Bank of Australia, may soon join the ranks of those CEOs who depart once a corruption scandal goes public.
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OFAC red cards Mexican footballer Marquez
A prominent Mexican football star finds himself on OFAC's black list for allegedly fronting for a known drug kingpin. Just when you thought soccer couldn't get any more dramatic.
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Looking to buy? Be sure and complete your due diligence
Tom Fox explores a recent report on wealthy American businessmen attempting to purchase London soccer clubs for a weekend outing and their due diligence duties.
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Halliburton, the FCPA, and effectiveness
Having a great compliance program means nothing if it exists only on paper. If you want to keep the DoJ and SEC happy, that program must also be demonstrably effective.
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Compliance includes anti-trust compliance
While the United States banks on anti-trust training, in other parts of the world—such as Germany—there is not such a strong prohibition against competitors’ collaboration. Reports, however, indicate that may be changing.
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Solitude as a leadership skill
A new book by Raymond Kethledge and Michael Erwin encourages leaders to take back a sense of control over their operations. While it is not always possible to unplug in today’s connected world, writes the Man From FCPA, taking some time to unwind and simply think can be a valuable ...
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VW enters a new penalty phase
A significant source of funding or loan guarantees for VW may have become impaired, making the emissions-testing scandal and the attendant penalty phase potentially even more damaging for the automaker.
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How Hui Chen prompted an evolution in compliance at the DoJ
Hui Chen’s time as compliance counsel at the DoJ’s Fraud Section was short and eventful and did a lot to move the needle on how the DoJ views corporate compliance programs.
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Compliance, risk, and the opioid scandal
The pharmaceutical industry may be the next victim of the opioid epidemic, as the government turns its focus on the pharmaceutical manufacturers themselves, not the addict or drug abuser.