All articles by Tom Fox – Page 20
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Second VW exec arrested: those pesky e-mails
As the recent arrest of another VW executive (this time in the United States) unfolds, The Man From FCPA Tom Fox ponders whether VW will actively assist U.S. law enforcement authorities in performing a substantive internal investigation.
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The Odebrecht enforcement action—the aftershocks
Have you been doing business with corruption-plagued Odebrecht? Better conduct a thorough internal investigation to ascertain if there are any red flags indicating suspicious payments, writes Tom Fox.
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Technology, compliance, and the breakdown of corporate silos
The Man From FCPA Tom Fox explores the recent Foreign Corrupt Practices Act enforcement action involving General Cable Corp. and its implications for a technology-driven compliance world.
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Michael Lewis’ ‘The Undoing Project’ and compliance
The Man From FCPA Tom Fox offers his take on the most recent Michael Lewis book, “The Undoing Project, A Friendship That Changed Our Minds,” which—Fox says—“should be studied by every compliance professional for its insights into how the human mind works.”
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Odebrecht-US leads a massive global corruption settlement
The Odebrecht and Braskem global corruption settlements portend a new level of international cooperation in both investigation and enforcement.
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When the regulators fail
Tom Fox looks at an untapped area of concern with the Volkswagen emissions scandal: Why did no EU regulator catch on earlier?
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The routineness of non-compliant conduct
Tom Fox explores a new book entitled “Why They Do It” from Eugene Soltes, the Jakurski Family Associate Professor of Business Administration at Harvard Business School, which shows a certain “mundaneness” to white-collar crime.
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Study shows effects of whistleblowers on enforcement
The Man From FCPA Tom Fox explores a recent academic study that found a link between information provided by whistleblowers and “heightened enforcement outcomes.”
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Compliance has become the heart of the business
Compliance has taken center stage in investors' eyes according to Tom Fox. Large institutional investors are beginning to evaluate companies by considering a mix of metrics, such as regulatory warnings, tangential civil lawsuit, and social responsibility. Fox has more.
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How JPMorgan Chase avoided prosecution over ‘Sons and Daughters’
At one time, it looked like JPMorgan Chase had landed in fairly hot water with its ‘Sons and Daughters’ bribery scandal. But for every misstep, says Tom Fox, there is a path to freedom.
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Did Wells Fargo Give Prudential a Black Eye?
Tom Fox epxlores how the business relationship between Prudential and scandal-ridden Wells Fargo put Prudential in hot water.
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The FCPA and ‘Islands of Honesty’
The Man From FCPA Tom Fox explores a recent article that hopes to answer the question: Why are so many governments around the world collapsing amid corruption scandals?”
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Under the FCPA, 'anything of value' means precisely that
A recent U.S. Supreme Court decision makes it very clear that when it comes to issues of potential bribery, absolutely anything that could be considered as having value is fair game as a potential agent of corruption. Tom Fox reports.
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Who watches the watchers?
The recent enforcement action against Big Four accounting firm Deloitte and its Brazilian arm details what happens when an auditor is willing to lie to the government and alter work papers on behalf of a client. But what might it be willing to do to hide bribery and corruption, asks ...
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Self-certified due diligence is fraught with danger
Tom Fox looks at further reverberations from the Malaysian sovereign wealth fund 1MDB scandal concerning one giant red flag: a reference provided by a third party to vouch for that third party.
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Ethics training and parking spaces
A parking space is seen as a definite perk for U.S. executives, but perhaps not so in other countries. Tom Fox looks at the recent case of former Daimler President Rainer Gärtner, who—while operating out of the firm’s China-based location—overreacted to improper use of his parking spot.
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Compliance on the VW board
Tom Fox explores the case of Hans Dieter Pötsch, chairman of the VW supervisory board, who could be held responsible if German prosecutors find the board had actual knowledge, but failed to keep shareholders abreast, of the emissions-testing scandal and its potential costs.
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Use of data in a best practices compliance program
Tom Fox discusses how data must be continually managed, tested, and recalibrated within an organization for it to be fully effective.
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Did they get the memo?
Tom Fox explores the case of Australian mining giant Rio Tinto, which recently terminated two top officials after an investigation into possible Foreign Corrupt Practices Act violations.


