All articles by Tom Fox – Page 5
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Blog
No piling on requires global disclosure and cooperation
To receive the benefits of no piling on, companies must fully disclose their conduct and cooperate with regulators across the globe.
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Blog
Mergers and corporate culture
Big mergers are in the news, with the union of telecom giant AT&T and vast multimedia firm Time Warner and Comcast’s $65 billion bid for 21st Century Fox being just two examples. With the recent Justice Department emphasis on corporate culture, it will be interesting to see what this season ...
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Blog
What is due diligence?
Due diligence is key to getting your third-party risk management program off the ground.
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ArticleIt could get messy for U.S. companies doing business in EU
Don’t be surprised if the EU uses new data privacy laws to combat any secondary sanctions it might face by the Trump administration for continuing to do business in Iran.
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Blog
What changed? FRC brings action in Autonomy scandal
The Financial Reporting Council has brought long-awaited charges against Autonomy executives for their role in the massive accounting fraud uncovered when Hewlett-Packard attempted to purchase the software firm in 2011.
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Blog
Executives behaving badly—at what cost?
FCPA violations from SocGen and Legg Mason may point to a new trend of holding the C-Suite accountable, but will voluntary resignations be seen as enough of a penalty?
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Blog
Best practices: Hiring a business sponsor for third-party relationships
A significant piece of the compliance regime is overseeing third-party business relationships, and the best way to keep them on track is to employ the business sponsor.
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Blog
Business justification for the use of third parties
Why is business justification for third parties so important? With the Department of Justice, Securities and Exchange Commission, and Internal Revenue Service all seeking such justification, companies should definitely make it part of the compliance process.
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Blog
The ZTE Department of Commerce Monitor: uncharted waters
As part of the resolution to free itself from a U.S. sanction, ZTE has agreed to the unique position of having a court-appointed monitor and one from the Department of Commerce, leading to concerns of a clash of ideas and authority.
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Podcast
Tom Fox podcast: Importance of code of conduct, policies and procedures, and internal controls
In the second of a series on the 10 hallmarks of an effective compliance program, Compliance Week columnist Tom Fox discusses the three components of written standards of a best-practices compliance program: the code of conduct, policies and procedures, and internal controls.
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Podcast
Tom Fox podcast: Setting the right tone at the top
In the first of a weekly series on the 10 hallmarks of an effective compliance program, Compliance Week columnist Tom Fox discusses the importance of senior leadership in setting the tone for the company.
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Blog
GDPR is live ... now what?
With GDPR now in effect, we should soon start to get some answers regarding its enforcement and how its private right to action will play out in the legal arena.
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Blog
Compliance in the middle is critical
One of the most important parts in the corporate hierarchy is the often-overlooked middle of an organization. Inside is an in-depth look at what tone in the middle should be.
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Blog
Improving your compliance strategy
Communicating your compliance strategy can be a critical problem when operationalizing compliance, but there are some best practices companies can follow.
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Blog
Avoiding and overcoming GDPR challenges
When GDPR becomes effective on May 25, compliance practitioners will have to be ready for those areas that will be most impacted by the regulatory change.
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Blog
Novartis GC resignation points to compliance themes
The resignation of Novartis GeneraI Counsel Felix Ehrat shows companies the importance of distinguishing between the legal and compliance functions and why you should always get a business justification before working with third parties.
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Blog
Wells Fargo charm offensive
New Wells Fargo ads in prominent business newspapers are an effort to let the world know the bank is cleaning up its act—but, without follow-through, it may not be enough.
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Blog
ZTE and the Arthur Andersen myth
Remember the myth of Arthur Andersen—that if you go to trial in a corruption case and lose, the company will be irreparably harmed? That myth may have arisen once again in the form of a U.S. president criticizing U.S. regulators for penalizing Chinese company ZTE.
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ArticleD&B shows the right way to handle an FCPA probe
The D&B enforcement action should be studied by every compliance practitioner for tips on preventing an FCPA issue and what to do if you find one.
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Blog
The benefits of tailored compliance training
A thoughtful look at focusing compliance training on an employee-by-employee basis could mean the difference in keeping corporate compliance on the right track.