All articles by Tom Fox – Page 5
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Blog
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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Blog
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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Blog
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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Blog
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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Article
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.
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Blog
Phase 2 in third-party risk management: the questionnaire
An essential piece of third-party risk management is “the questionnaire,” which companies should garner on behalf of all their third-party relationships at the start of the union in order to move forward with all the anwers.
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Blog
Condos, corruption, and compliance
While President Trump promised condos in North Korea as a part of his negotiations with North Korean Supreme Leader Kim Jung Un, it doesn’t mean companies will have an easy time doing business in the country, which ranked as “highly corrupt,” on the 2017 Transparency International Corruption Perceptions Index.
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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.