All articles by Tom Fox – Page 21
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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.
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Going to trial in an FCPA case-it’s just a trial
Tom Fox explores the reason behind why there’s a lack of trials for corporations when it comes to Foreign Corrupt Practices Act violations.
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The JPMorgan FCPA settlement and the Fed
The recent JPMorgan Chase FCPA settlement resulted in $264 million in fines, with a portion being paid to the U.S. Federal Reserve Bank. While some contend a Fed fine should not be considered FCPA, Tom Fox says: If it walks like a duck and quacks like a duck, it is ...
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Will Brazil’s ‘car wash’ end?
The Man From FCPA Tom Fox explores recent reports surrounding Brazilian legislative figures trying to obstruct ongoing corruption investigations.
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Two top compliance programs get together
The merger of General Electric and energy services company Baker Hughes Inc. combinews two firms that are recognized as having the very top compliance programs in the energy industry and indeed across the country. Tom Fox reports.
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Artificial intelligence meets compliance
A look from Tom Fox at how artificial intelligence is changing the face of compliance in order to incorporate cultural values into the hiring process.
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What’s in your (corporate) wallet?
With the recent scandal at Wells Fargo, The Man From FCPA Tom Fox discusses the importance of finding out what’s in your corporate wallet, i.e. what information is in your files that could point to issues that might lead to regulatory violations.
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Where is the Justice Department headed—no tea leaves needed
Tom Fox explores what Justice Department Compliance Counsel Hui Chen has in store for enforcement in light of recent remarks from Assistant Attorney General Leslie Caldwell.
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1MDB-a truly international fight against corruption
Tom Fox looks at the alleged looting of Malaysian sovereign wealth fund 1MDB and the implications it has for fighting global corruption.
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Conflicts of interest: The EU and the revolving door
Tom Fox explores the recent appointment of former EU commissioner Jose Manuel Barroso to non-executive chairman of Goldman Sachs’ London-based investment bank. Is the move a violation of conflict of interest rules?
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Stopping little lies before they become FCPA violations
What makes a fraudster? And how can a fraudster’s actions lead to larger complications for your corporation’s Foreign Corrupt Practices Act policies? Tom Fox sets out to answer these questions.
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Corruption becomes a political issue in Mexico
Tom Fox looks at Mexico’s struggle to turn itself around, beginning with a political discussion and the introduction of FCPA-like anti-corruption regulation. Is it a turning point or a false start?
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Tales of crocodile tails under the FCPA
While the FCPA makes clear it prohibits providing anything of value to a foreign governmental official, who’s to say what has value? For U.S. officials, it could be jewelery, cash, or sports tickets. But for Chinese executives, it could be something more exotic, say ... crocodile meat? Tom Fox has ...
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Is a cup of coffee a reportable FCPA violation?
What’s next on the list of FCPA violations, a cup of coffee bought for a custom official while you await inspection? Tom Fox ponders that question after reading about Lennox International’s $475 facilitation payment Justice Department disclosure.