All articles by Tom Fox – Page 21
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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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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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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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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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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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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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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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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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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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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.
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Just who are your friends?
Corruption in Hollywood? Tom Fox explores the controversy surrounding financing of the film, The Wolf of Wall Street, which the Justice Department claims was funded by the looted Malaysian sovereign wealth fund 1MDB.
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Tell us everything you know
Getting credit for cooperating with the Department of Justice is getting a whole lot tougher. Tom Fox explores.
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Galaxy Note 7 and an independent set of eyes
Tom Fox looks at the case of Samsung—which bucked the regular procedures used by other telecoms and self-tested its Note 7 batteries—to see how independent oversight would have made the difference in the outcome.
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The Nu Skin FCPA enforcement action reminds all of the cost of non-compliance
Tom Fox looks at the recent enforcement action against Nu Skin: a one-time bribe equals a one-transaction enforcement action.
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At PDVSA, the costs of corruption extend to bond swaps
Tom Fox explores anti-corruption lessons gleaned from Venezuelan national energy company Petróleos de Venezuela’s failed debt swap offer.
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Is Weatherford under another FCPA investigation?
A recent SEC announcement regarding a $140M penalty Weatherford paid to settle charges that it inflated earnings mentioned a continuing investigation. What’s curious, notes Tom Fox, is that those investigating are known for their work in FCPA enforcement.
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Was the GlaxoSmithKline FCPA resolution a missed opportunity?
Tom Fox questions whether U.S. regulators missed a chance to illustrate how they would give credit for anti-corruption prosecutions done by other governments in the case of GlaxoSmithKline’s China subsidiary’s recent FCPA resolution.