All articles by Tom Fox – Page 31
-
Blog
Painful Lessons Learned From Alstom, Avon Settlements
Two long-standing FCPA investigations—one into Avon, the other into Alstom—wrapped up in December, with results sure to alarm any audit committee. The fines were huge, the investigation costs just as large and, above all, the costs of non-cooperation were demonstrated to be painfully high. Inside, Compliance Week columnist Tom Fox ...
-
Blog
Janus, COSO, FCPA Compliance and Enforcement
The U.S. Sentencing Guidelines have long been one path to kinder treatment from the Justice Department for FCPA violations. On the civil side enforced by the SEC, something similar may be emerging: the COSO 2013 framework for effective internal control. How different are those two paths? Not as much as ...
-
Blog
How Layne Christensen and Hewlett-Packard Earned Favorable Treatment After an FCPA Charge
When Layne Christensen, a global water management and construction company, and tech pioneer Hewlett-Packard were targeted for violating the Foreign Corrupt Practices Act, they both escaped harsh punishments by cooperating with enforcement authorities. Their actions serve as a how-to for earning cooperation credit. Inside, columnist Tom Fox runs down their ...
-
Blog
For FCPA Compliance, Don’t Forget the Internal Controls
They have been there all along, hiding in plain sight: the Foreign Corrupt Practices Act requirements for internal controls.The problem is that most compliance practitioners have not been reading them too carefully. What are internal controls in a FCPA compliance program? Aaron Murphy, a partner at Akin Gump and author ...