All articles by Tom Fox – Page 22
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The FCPA and the fight against terrorism
Tom Fox looks at the U.S. government’s linking of corruption and terrorism and its intention to use the FCPA as incentive to enact and enforce strong international and domestic anti-corruption and anti-bribery laws.
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Will Wells Fargo lead to more whistleblowing?
Tom Fox looks at expert opinion on whether the recent accounting scandal at Wells Fargo will be used to enhance whistleblower laws and regulations.
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Of soccer, cheating, and Sam Allardyce
The sacking of English football manager Sam Allardyce for explaining how to cheat at football to an undercover sting newspaper operation is an important reminder why the top of an organization sets the tone, says The Man From FCPA Tom Fox.
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Singapore’s increased AML scrutiny might affect everyone
As Singapore considers cracking down on money laundering, the impact of such a move may ripple far beyond that nation’s own banking system. Tom Fox has more.
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Reflections on the compliance profession from the SCCE Compliance and Ethics Institute
The Man From FCPA Tom Fox reflects on the changing role of the compliance practitioner and other lessons learned at the recent 15th annual SCCE Compliance and Ethics Institute in Chicago.
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Sir Andrew Witty successor named: GSK revisited
Tom Fox looks at Sir Andrew Witty’s career as chief executive of GlaxoSmithKline, as the CEO recently resigned and was replaced by Emma Walmsley.
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Whistleblower awards and new scrutiny of SEC enforcement
The SEC’s successful whistleblower bounty program is raising some very interesting questions about the future of whistleblowing in general. Tom Fox reports on the agency’s recent enforcement actions.
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Memo to Telia, Deutsche Bank: Do not negotiate with the DOJ in public
While Telia Co. and Deutsche Bank are looking to publicly war with the Justice Department over upcoming penalties, they should be learning by Avon Product’s example, says Tom Fox—the firm initially suggested a $12M fine and ended up paying a cool $135M.
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Why pre-acquisition due diligence and post-acquisition remediation are so critical
Tom Fox looks at a recent SEC settlemenf for and FCPA enforcement action against Jun Ping Zhang, which makes clear the need for robust pre-acquisition due diligence.
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The (non) myth of the 5,300 rogue employees
The Man From FCPA, Tom Fox, asks why it is always the employee’s fault when a corporation engages in fraudulent activity leading to regulatory fallout. Perhaps the CEO of Wells Fargo, responsible for the firing of 5,300 “rogue” employees for fraudulent activity, has the answer.
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SFO brings charges in Tesco accounting scandal
Tom Fox examines the Serious Fraud Office’s recent indictments against three individuals from the October 2014 Tesco scandal in which the British grocery chain overstated earnings by fraudulently accounting certain revenues received back from suppliers.
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Internal controls: trust but verify
Tom Fox looks at the recent scandal at Wells Fargo leading to the Consumer Finance Protection Board’s $185 fine and the firing of more than 5,000 employees after basically telling them: “It’s OK to break the law, as long as we make money.”
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Perception, reality, and global anti-corruption enforcement
Tom Fox looks at scandals involving Swedish business empire Industrivärden and Apple that point to an increasing need for good compliance programs in an age of corruption and social media.
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When good-intentioned sales incentives go bad
When do sales incentives move from the realm of legal to the realm of the nefarious? When do company communications become so code-word laden as to demonstrate corrupt intent? Tom Fox explores this latest trend that occurred at Fiat-Chrysler.
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Compliance lessons keep coming from HP/Autonomy deal
HP’s legendarily bungled acquisition of U.K. software company Autonomy continues to provide valuable compliance lessons as well as one heck of a corporate governance horror story. Tom Fox reports.
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Internationalization of football and anti-corruption enforcement
Tom Fox explores the recent bid by a Chinese state-controlled investment fund to purchase the Liverpool Football Club and how it will be impacted by the U.K. Bribery Act.
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Do the FCPA rules make sense?
How many rules are too many? How complicated are the rules to follow? These are questions Tom Fox explores in the context of the Foreign Corrupt Practices Act. Fortunately, the answer, he says, is quite simple—do not pay bribes.
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Will VW impact international settlements for bribery and corruption?
The Man From FCPA Tom Fox explores the fallout from VW’s emissions-testing scandal and how the company will make restitution going forward to its customers, dealers, and other stakeholders.
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Tone at the top really does matter
The Man From FCPA Tom Fox looks at the case of disgraced pharmaceutical company Valeant and what new Chief Financial Officer Paul Herendeen has planned for the company’s future.
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Target and Walmart show that supply chain risk is everywhere
The bigger the company, the bigger the supply chain risk. Just ask Target and Walmart, which recently had to confront this issue head-on over fake Egyptian cotton bedsheets. More from Tom Fox.


