All articles by Tom Fox – Page 15
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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.
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New twist in the Volkswagen investigation
In one of the more interesting and recent twists to the emissions-cheating scandal, Volkswagen has accused a group of fellow German car manufacturers of collusion over the diesel engine scandal, now almost two years old.
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Wells Fargo and its data privacy faux pas
Wells Fargo continues to be in the news these days (and not for the better) in the way of its reputation.
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Change in prosecutorial strategy in VW case?
The recent arrest of an italian citizen in Germany, a former VW employee, may mean the government intends to bring charges against lower-level employees in an attempt to get them to flip on senior employees who were involved in the fraud.
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First step to end the Car Wash investigation?
The will to continue the fight against institutional corruption in Brazil may be waning. From the perspective of The Man From FCPA, it appears that it is the beginning of the end for the seismic change that has come over the country starting with Operation Car Wash.
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Once again, no judicial review of DPAs
While there will be no official review, a recent case where a federal district court approved a limited release of a Monitor’s report from the financial institution HSBC will have an impact on the court’s treatment of DPAs.
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FCPA Pilot Program leads to two 2017 declinations
The FCPA Pilot Program declinations we have seen so far in 2017 both make substantial additions to the precedent for how to avoid prosecution under the FCPA.
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Shell companies in the U.S.—beginning of the end?
The Man From FCPA explores the issues surrounding shell companies and, in particular, money laundering enforcement.
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Of Barclays and DPAs
Is Barclays too big too jail? Tom Fox explores the banking giant’s involvement in the bailout scandal during the 2008 financial crisis.
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Don’t speak at anti-corruption event, then demand a bribe payment
Well, that’s awkward. A look at the ironic case of Colombia’s top anti-corruption prosecutor, who was arrested in Miami for attempted corruption through extortion of a criminal defendant.
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Will Odebrecht survive?
A look at how Odebrecht is trying to salvage itself from the ruins of its corrupt run as one of the leading construction companies in the Americas.
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FCPA enforcement-giving confidence to financial markets
Judge Stanley Sporkin’s foresight in enacting the Foreign Corrupt Practices Act in the correct manner is a big reason behind why there is a large amount of confidence in U.S. companies.
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SFO brings charges against bankers
The Man From FCPA takes an in-depth look at the Serious Fraud Office case against four former Barclays executives for illegal money lending.
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The power of social media
Last week saw the resignation of Uber CEO Travis Kalanick, and it all began with a blog post.
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Making data protection and privacy a business process
In May 2018, the European Union’s General Data Protection Regulation (GDPR) will come into force, which means that U.S. companies that do work internationally need to be very aware of this date and plan accordingly.
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FCPA protects the safety and health of Americans
Some continue to believe that bribery and corruption that occurs outside the United States does not concern the United States, its laws, or is even worth the time of U.S. law enforcement agencies. This myopic view belies both the inter-connectedness of the world’s economy and the facts on the ground.
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Compliance in the 21st Century: Welcome to ComTech
Automation and artificial intelligence stand to increase efficiency in compliance by a quantum leap. But human compliance officers still have a role to play … if they prepare for it now.
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Sailing, cycling, and compliance
A lesson from the America’s Cup Emirates Team New Zealand reveals that exploring past methods can improve your future compliance policies and ensure against possible Foreign Corrupt Practices Act violations.