All articles by Tom Fox – Page 4
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A fine mess in Brazil (and Houston)
A legal battle between Vantage Drilling and Petrobras, Brazil’s state-owned oil company, has put a new twist on contract challenges and FCPA violations
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What is a business relationship?
The Man From FCPA ponders the FCPA considerations of electric-car company Tesla putting the squeeze on its suppliers by asking them to refund monies Tesla had paid to them, as far back as 2016.
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The ‘how’ question in due diligence
A clear lesson to be learned from the Theranos scandal is when conducting merger due diligence, make sure to determine how a new partner conducts itself and its business.
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Evaluation of third parties
Compliance practitioners at GE Oil & Gas discuss the process by which GE reviews the risks around each of its third parties.
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Law firm files alleged evidence of bribery against former client
U.K.-based mining giant Eurasian Natural Resources Corp. is suing its former counsel and U.K. regulator the Serious Fraud Office for their complacency in leaking information about an investigation into the company for alleged bribery and corruption.
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Why HR compliance is critical to creating trust
The recent departure of Uber’s head of human resources suggests the company’s new speak-up cultural might not be all it’s cracked up to be.
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Will a Goldman partner flip?
The former head of Goldman Sachs southeast Asia is reportedly in discussions with the Justice Department and will likely plead guilty to federal charges regarding his involvement with the 1MDB corruption scandal. What will his involvement mean for the company, which continues to deny culpability?
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Irony, FCPA enforcement actions, and M&A
Boeing’s planned acquisition of Brazilian company Embraer’s commercial jet business and LyondellBassell’s possible acquisition of Brazilian entity Braskem highlights an ironic twist to the FCPA: An enforcement action could be so financially draining that your company is forced to sell all or parts of itself, but results from that same ...
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What is the cost of a subpoena?
Glencore has seen a drop in its share price, which could be related to the Justice Department having issued a subpoena for possible FCPA violations in the Democratic Republic of Congo, Nigeria, and Venezuela.
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Hiring and the FCPA
The Credit Suisse FCPA enforcement action reminds us all again that it is not the hiring of family members or close friends of a foreign government official or employee of a state-owned enterprise that is illegal under the FCPA, only those hires made with corrupt intent.
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Incorporating compliance into long-term corporate strategy
How can a board of directors work to incorporate the compliance function into a long-term business strategy of the organization? Tom Fox has a few ideas.
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Payroll controls and compliance
How can payroll help when operationalizing a compliance program? Tom Fox explores payroll’s role and the four key areas that should be considered when reviewing compliance goals.
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The continuing problem of shell companies
Businesses must conduct more robust background checks and must work to improve their internal controls around all third parties to make sure one does not slip through the corporate cracks and cause great damage.
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Check your Hermès handbags and bank accounts
The scope of the corruption that befell 1MDB funds continues to widen, with an investigation uncovering a staggering amount of loot from the home of former Prime Minister Najib Razak. For companies doing business in or with Malaysia, now is the time to make sure all operations are free from ...
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Machine learning and anti-corruption compliance
Behavioral analytics, coupled with machine learning will enhance anti-corruption compliance programs and the company will run more efficiently, as it will allow an organization to more closely track its overall spend going forward.
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Whistleblowers and building trust
It is now more important than ever for companies to take seriously internal whistleblower reports, get the reports into the hands of the corporate functions that can triage and investigate such information, and keep the whistleblower in the loop more fully as to the status of the investigation.
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Shell companies and the who of corruption
A key part of any fraud scheme are the attempts to keep it hidden, and many companies set up shell companies to do just that. A look at why shell companies can shield bad actors from the public record.
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Asking questions about your third-party process
When regulators come knocking, it’s important to have the right protocols in place. Knowing what questions to ask can be a big help to companies when implementing a third-party due diligence process.
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The importance of compliance contract terms
Making sure third-party contracts contain appropriate compliance terms and conditions can help save companies time and money down the road.
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GM’s Shawn Rogers speaks candidly on training transformation
Compliance Week columnist Tom Fox recently sat down with Shawn Rogers, lead counsel, compliance training and communications at General Motors, to discuss the innovative steps GM has taken toward improving compliance training.