All articles by Tom Fox – Page 27
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Blog
Another bank under FCPA scrutiny for its hiring practices
Financial services providers face unique corruption risks when seeking to win business in international markets. This includes a traditional form of back-scratching: the hiring of children or other close family members of prominent foreign officials. Only now the SEC has made it clear that such practices can and will invite ...
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FIFA dribbles up the pitch toward reform
As FIFA continues to battle its landmark corruption scandal, it has elected a new President and passed a series of structural and process reforms to bring the organization into the 21st century and demonstrate to U.S. authorities that it really is going to change from its prior culture. But is ...
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Fighting corruption in the light of day
Image: FIFA isn’t the only major sporting organization with corruption problems. The United States Tennis Association has created a problem for itself by allowing an umpire, who was suspended for corruption, to continue to officiate at the 2015 U.S. Open. Inside, CW’s corruption blogger Tom Fox examines USTA’s reasoning behind ...
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When are campaign contributions FCPA violations?
A recent article in the Financial Times by Simon Kuper, titled “How to buy a foreign election” reminded me that the FCPA specifically makes illegal more than simply bribing a foreign government official or some employed by a state owned enterprise to secure an improper advantage. The FCPA also makes ...
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Justice Department concludes $795M FCPA action against VimpelCom
Image: Dutch telecom giant Vimpelcom will be hit with nearly $800M in fines, penalties, and disgorgement of profits and prejudgment interest from its huge FCPA case where it spent millions to bribe its way into the Uzbekistan marketplace. Tom Fox looks at the details of the Justice Department’s FPCA enforcement ...
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Corruption can give you a very bad few days
Title: Corruption can give you a very You know it is going to be a bad day when you see your company’s name splashed across a BBC investigative report into alleged payment of bribes to secure business contracts. However, your day can get considerably worse when US congressmen, call ...
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€30 million for cup of tea? Good work if you can get it
FCPA blogger Tom Fox looks at an unfolding scandal that involves a murdered Mongolian paramour, a contract for submarines, embattled Malaysian Prime Minister Najib Razik, middleman Abdul Razak Baginda, and the most lucrative cup of tea in recent memory.
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SciClone Settles with the SEC on FCPA Enforcement Action
Title: SciClone Settles with the SEC As SciClone Pharmaceuticals settles with the SEC for FCPA violations committed by a Chinese subsidiary, Tom Fox considers how the finer points of granting favors to government officials merits greater compliance scrutiny.
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The Greek Culture of Corruption
Envelopes stuffed with cash and entire industries poised to take action against the first sign of whistleblowing are just two of the hallmarks of the endemic corruption that bedevils the entire Greek economy. What can be done when compliance isn’t just absent in a country, but actively avoided as a ...
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The SAP and Garcia FCPA Enforcement Actions - The Government Speaks, Are You Listening?
As the SEC concludes its Foreign Corrupt Practices Act investigation into suspected illegal activity by former SAP International Vice President of Global and Strategic Accounts Vicente Garcia for bribery and corruption in sales to certain government officials in Panama, we are seeing some clear signs about where FCPA enforcement will ...
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The Swiss Tackle International Corruption
Last week the Swiss government announced that it had found improprieties in the conduct of the Malaysian government’s sovereign wealth fund, 1Malyasia Development Berhad. The problem for the government of Malaysia is that the sovereign wealth fund is headed by the country’s Prime Minister, who had over $700 million deposited ...
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Treasury Moves to Shine a Light on Real Estate Transactions
Recently, the U.S. Treasury Department said it would begin demanding to know the names of folks behind the shell companies, which ultra-wealthy foreigners use to hide behind multimillion-dollar real estate purchases. Efforts by the U.S. Treasury Department to police more closely large cash purchases of real estate as a method ...
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What Will Wal-Mart Wrought?
Please forgive the mixed tenses in the title but I have been thinking about what the Wal-Mart anti-corruption matter might mean at the end of the day.
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February 1 Deadline for Data Transfer Clarity
February 1 is a date that all U.S. and EU compliance practitioners need to circle. It’s the deadline for the U.S. Department of Commerce and the European Commission to reach a deal regarding the transfer of data from EU countries to the United States. As of now, the two still ...
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Board of Directors and Line of Sight Into Compliance Trends
Image: A board of directors must set the appropriate tone at the top for any organization. Yet it must do more than simply set the tone, sit back, and do nothing. A board needs to take a hard look at the information it is being presented and tell management to ...
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Use of Compliance Data an Anti-Trust Violation in Europe?
How did the collection of Big Data somehow run afoul of European anti-trust regulations? The Man from FCPA takes a look at one of the more puzzling regulatory decisions to come out of the Eurozone recently, and at what it means for compliance officers everywhere.
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Mike Oxley, the FCPA, and the Fight Against Terrorism
When the Foreign Corrupt Practices Act became law years ago, it was never intended to be used as a tool to fight terrorism. But as recent terror activity has illustrated, corruption and terrorism go more than hand in hand; the first helps to create the second. And as we look ...
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Tesco’s Tone at the Top and the Myth of the Rogue Employee
Image: We often hear of a rogue employee who is really to blame for a major corruption scandal, but how often do bad apples really cause the problem? And how much is a wider corporate culture—perhaps even one that allows for, or encourages, rogue actors—a more likely source of problems? ...
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Compliance Convergence: the Consequences of an Export Control Failure
When a Hellfire missile intended to be shipped from Germany to the United States accidentally ends up in Cuba, more than a few eyebrows raised over it, especially since such sensitive cargo was handled by multiple shipping companies that never seemed to check the manifest or wonder why one of ...
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Are VW Execs Breathing Easier Now?
Image: Senior executives at Volkswagen took a very deep sigh of relief when the Justice Department announced a civil suit (?a suit many say is a cakewalk as opposed to the tougher policy set by the Yates memo) against the company for damages from its emissions fraud scandal. In addition, ...