All articles by Tom Fox – Page 16
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Tip of the (compliance) hat to Hui Chen
A look at Hui Chen’s career at the Department of Justice, serving as the compliance counsel and, most importantly, putting the compliance function front and center in the fight against FCPA violations.
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Compliance and risk management as a competitive advantage
The Man From FCPA explores Amazon’s recent foray into banking that effectively demonstrates how the risk management aspect of compliance can be used as a competitive advantage.
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When corruption is endemic and structural
The recent scandals involving JBS, Odebrecht, and Petrobras seem to imply that once Brazilian politicians go on the take, they stay on the take. Time for Brazil to update its anti-corruption regulations.
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Should compliance training be humanities- or business-based?
The Man From FCPA explores the question of whether a compliance professional benefits more from a humanities-based education or a business school-based education.
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The Haider FinCEN enforcement action and CCO liability
Does the recent FinCEN enforcement action against Thomas Haider, Moneygram’s CCO, portend a shift in Justice Department enforcement strategies?
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Under FCPA investigation? Reconsider travel to the U.S.
The arrest of VW’s former top emissions compliance manager, Oliver Schmidt, who was departing the United States after a Christmas holiday and was thrown in jail and denied bail, will make it less likely for foreign countries to send their citizens to face U.S. justice.
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The case for robust FCPA enforcement
Two recent corruption scandals emanating from Brazil highlight the direct impact corruption can have on U.S. citizens and serve as telltale examples of why a robust FCPA enforcement regime is in the interest of the United States.
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How Rome and Athens inform today’s company
The differences in roles between a corporate legal department and a corporate compliance function are akin to the differences between Rome and Athens.
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CW 2017 event reveals few have read Justice Dept. Evaluation Guidance
A small percentage of the audience at Compliance Week 2017 had read the Justice Department guidance on evaluations. What are they missing, and why the delay?
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A Futurist on compliance
At Compliance Week 2017, Futurist Dr. Brian David Johnson started the show with his talk about artificial intelligence, the future of the compliance profession, and the position of the chief compliance officer.
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Boards, compliance, and ongoing strategy
Board members must learn to take a more active role to not only prevent scandals—but when they do arise, ask tough questions of management and the compliance function about what is being done to remediate the situation.
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The intersection of corruption and the environment
Petrobras is attempting to sell a petrochemical plant that is “notorious for its multiple accidents, fires, and emissions releases,” according to reports. At issue? No environmentally responsible company would be interested in the doomed facility.
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How do you determine judgment at the CEO level?
In the case of Barclays CEO Jes Staley, judgment seems to be lacking, as the executive first attempted to unmask an anonymous internal whistleblower and now has intervened in a Brazilian private-equity deal involving his brother-in-law.
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FIFA fires its own investigators
When it comes to brassiness, one really cannot do much better than FIFA. After having survived one of the world's greatest scandals, the international governing body of football is replacing the leadership of its ethics committee, in effect dismissing the judge and the prosecutor whose investigations resulted in the suspensions ...
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A good day for the rule of law in Romania
Romania sees additional protests, as government tries to sneak more laws into place that would weaken the fight against corruption.
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Will KPMG pay for Rolls-Royce’s corruption?
More negative publicity for KPMG, as the Wells Fargo auditor now faces additional scrutiny in light of the Rolls-Royce scandal—will the Big Four firm be made accountable?
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‘Being data compliant does not equate to having data security’
Protecting your data involves more than simply following the paper program rules and regulations—you actually must focus on data security.
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Uganda—a demand side response to corruption
A look at corruption in Uganda and the government’s fear that the high level of corruption is making life worse for citizens and driving out foreign investment.
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United Airlines: using a compliance framework to further customer relations
United Airlines has been handed some positive compliance lessons from its recent public relations faux pas, including the forcible removal of a passenger, but will the company follow through on its pledge to make good on customer relations?
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Corporations and the financing of terrorism
The recent case of LafargeHolcim’s involvement in keeping a cement facility in Syria safe and operational during civil war has raised questions regarding a company’s responsibilities for ensuring monies it pays out do not go to fund terrorism.