All articles by Tom Fox – Page 24
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Empathy might be the secret ingredient your compliance program needs
Being a great compliance officer requires more than strong analytical skills and acumen. It requires soft skills like emotional intelligence, too, since compliance is ultimately all about people.
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For ENI, business risk, geography, and political risk all come together
How does a company assess its risks and, more importantly, how does it manage them? That’s the question FCPA blogger Tom Fox hoped to answer recently when he explored the case of Italian energy company ENI’s focus on doing business in Africa—known for being politically risky—which put some investors ill ...
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Bribery a plus for small business in South Korea?
Small businesses in South Korea object to new anti-corruption laws, claiming their implementation will hurt sales of luxury goods for bribes. Tom Fox explores further.
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FCPA issues arise at Goldman trial in London
There is nothing quite like a trial to bring all kinds of information to light that various parties would rather keep out of view. Goldman Sachs is now learning that the hard way in a suit regarding Libya’s sovereign wealth fund that has some serious FCPA implications. Tom Fox reports.
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A second corruption scandal arises in Brazil
Most of Brazil’s corruption focus over the past couple of years has been around Petrobras and the fallout from Operation Car Wash, but a second corruption scandal (dubbed Operation Zelotes) has arisen in Brazil that could be equally massive—this one relating to tax evasion by not only Brazilian companies, but ...
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Quid pro quo and FCPA enforcement
The Supreme Court’s reversal of the public corruption conviction of former VA Governor McDonnell should not have any effect on FCPA enforcement going forward. Tom Fox has more.
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When is contract price a risk?
Does a low bid contract present a compliance risk? Tom Fox examines what could go wrong now for Panama with the grand opening of the Panama Canal.
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Compliance front and center
The SEC and Justice Department have made it clear that it will no longer be adequate for companies merely to have a compliance program in place; it must actually be taken seriously from within and given the power and resources to do its job. Tom Fox explores.
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At one bank, lax compliance and internal controls are a 'cancer'
The Man from FCPA has seen a lot of strong statements from top management, but when a chief executive likens non-compliance to cancer, you know it is serious. But last week, Bill Winters, the chief executive of the UK bank Standard Chartered, did just that when he announced that he ...
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WADA and its non-response to whistleblowing
What are the implications of an entity not responding to allegations, which come to its attention through a whistleblower? In the FCPA world, such corporate behavior can lead to significant legal and financial consequences. The Man From FCPA was therefore intriged by recent reports that the World Anti-Doping Agency (WADA) ...
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VW’s Dieselgate has finally reached the automaker’s C-Suite
The VW emissions-testing scandal has reached the embattled automaker’s C-Suite. It was only a matter of time. Tom Fox reports.
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Responsibility under the FCPA: persons vs. systems approach
How your company considers Foreign Corrupt Practices Act violations will inform its response. Inside, FCPA blogger Tom Fox examines the differences between a persons versus a systems approach when it comes to tackling those violations.
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Lax controls—a cancer at one bank
Bill Winters, CEO of the U.K. bank Standard Chartered may have set a new precedent for taking a hard stance on ethics and compliance recently, when he penned an angry memo to 1,500 top managers announcing steps he has taken to “stamp out the cancer of complacency and lax controls” ...
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Of shell companies, law firms, and the FCPA
An interesting development in the continued fallout from the Panama Papers may portend a new trend in Foreign Corrupt Practices Act enforcement. Tom Fox takes a look at NML Capital’s lawsuit against Mossack Fonseca for obstruction of justice.
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On the myth of the ‘rogue employee’
Companies often use the myth of the “rogue employee” to try and absolve themselves from liability. But organizational wrongdoing is rarely the work of just one person, says FCPA blogger Tom Fox. More from Fox inside.
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Want evidence about the FCPA Pilot Program?
Do you want to see evidence of the effectiveness of the Justice Department FCPA Pilot Program? Read on ...
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At FIFA, things are only getting worse
The FIFA corruption scandal continues to rock the world of international soccer with new allegations of wrongdoings by former president Sepp Blatter (above) and his cronies. FCPA blogger Tom Fox explores the conflicts of interest that arise when those in charge set, negotiate, and approve their own salaries.
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The Panama Papers: of shell companies and tax evaders
Long before the now infamous Panama Papers scandal made the headlines, Ryan Hubbs, a senior manager of fraud investigation and dispute services at EY, penned an article about shell companies that still resonates. Tom Fox discusses how this and other media can help companies avoid the same tragic fate.
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Should data thieves be compensated?
Under what circumstances should you reward a data thief who exposes criminal activity? Tom Fox looks at the case of Hervé Falciani, who was employed at the bank HSBC and stole the list of persons who banked there, including those who did so to engage in tax evasion.
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Tone at the top and (former) CEO consulting
What does retaining a disgraced CEO as a consultant tell you about tone at the top?