All articles by Tom Fox – Page 6
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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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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.
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Uber promises to ‘move forward,’ but still doesn’t have CCO
Uber launched a new ad campaign in which it vows to “move forward” and “always do the right thing,” but the company still does not have a chief compliance officer (CCO) to make sure it delivers on that message.
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Checklist for CCO direct reports
Inside are some factors to consider when assessing chief compliance officer direct reports and what the Justice Department expects from the direct reporting process.
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Malaysia gets new PM; further probes of prior regime coming
The election of a new Prime Minster in Malaysia has heralded a potential investigation into the allegations of massive corruption carried out by the prior administration surrounding the country’s sovereign wealth fund, 1MDB.
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Not-so-neutral Switzerland probes 1MDB
Switzerland has joined the investigation into Malaysia’s state development fund 1MDB in what could be the first steps toward heightened AML stratagems for the often-detached country.
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What signal will Germany send on VW?
What effect will the U.S. indictment of former Volkswagen CEO Martin Winterkorn have on German prosecutors? Will Germany have the desire to indict and try the former head of the world’s largest auto manufacturer and pride of Germany?
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Learning lessons from FCPA enforcement actions
Two FCPA enforcement actions against Panasonic and Hewlett-Packard Mexico are good reading for the compliance practitioner and offer lessons in stamping out fraud.
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Autonomy verdict and FCPA defenses
A recent case involving Autonomy and Hewlett-Packard shows that it is not the bribe receiver’s conduct but the bribe payor’s conduct that matters.
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Operational excellence for better compliance
By focusing on the business process nature of compliance, you can create a more effective compliance regime.
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The ‘20 percent’ lesson learned from Panasonic Avionics
Compliance practitioners take note: Cooperating with FCPA investigators was literally worth millions to Panasonic Aviation.
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How regional committees can strengthen compliance culture
Implementing a regional model can more effectively ensure employee and third-party compliance with your code of conduct by integrating compliance into every aspect of a company’s functions and generating the necessary information to continuously improve your program.
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Sometimes, a fine isn’t enough
U.S. regulators want companies to take firm disciplinary action against employees who are involved directly—or even indirectly—in the conduct at the heart of violations.
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Moving from operationalized compliance to connected compliance
The Man From FCPA explores how and why companies should move to a system of “connected compliance,” allowing them to take on more risks and more efficiently run the business.
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The fight against worldwide corruption
When banks and regulators work together to halt the transfer, hiding, and parking of corrupt funds, the war on corruption takes one more giant step forward.
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Implementing and maintaining a successful compliance program
There are three key areas that can help boards of directors to establish and maintain an effective compliance program—structure, culture, and risk management.
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It never pays to lie ... just ask ZTE
The Man From FCPA is continually reminded that much of the basis of compliance is grounded in wisdom imparted by our parents. Today, we are reminded of one of the most basic ones: Do not lie. That lesson apparently did not reach Chinese state-owned telecom company ZTE.
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The cost of doing business with PDVSA
With the tightening of sanctions by the United States around Venezuela and PDVSA, there will only be more scrutiny going forward for those that do business with the state-owned oil company.
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What will be the cost to KPMG for South Africa failures?
The unraveling of KPMG in South Africa drives home a key point for any company that has done business in the country during the Zuma presidency.