All articles by Tom Fox – Page 9
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How suppliers facilitate fraud and corruption
Compliance officers should always remember there is a bribe receiver in a corruption case. That is why it is important to know not only your third party, but also with whom you are doing business.
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What is a conflict of interest?
A look at the case of Dr. Brenda Fitzgerald, the now former head of the Center for Disease Control, who invested in tobacco stocks after she became director.
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Compliance tone at the bottom
Even with a great tone-at-the-top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the “tone at the bottom.”
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Using investigative findings as the basis of remediation
There is nothing like an internal whistleblower report about an FCPA violation to trigger the board of directors and senior management attention to the compliance function and the compliance program.
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FIFA sends a letter
Under the FCPA there must be more than simple communication of instructions to not engage in bribery and corruption. Yet, FIFA only wagged its finger and said “do not engage.” Makes one wonder if the organization is actually ready to change.
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South Africa reminds the FCPA covers political parties
For any company doing business in South Africa, all your contacts with the African National Congress have FCPA implications; This means all the investigations you might be performing for contracts with the South African government, anything associated with the Gupta family or state-owned enterprises, should be assessed for ANC contacts ...
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Why board oversight matters, in investing and compliance
The case of Outcome Health is a clear lesson for the anti-corruption compliance practitioner: Levels of oversight not only provide a backup to make sure that no mistake should slip through, but also the rigor of financial oversight.
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Tone in the middle of an organization
What should the tone in the middle be? This role is critical because the majority of company employees work most directly with middle, rather than top management and, consequently, they will take their cues from how middle management will respond to a situation.
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Financial incentives in a compliance program
You must be able to evolve in your thinking and professionalism as a compliance practitioner to recognize the opportunities to change and then adapt your incentive program to make the doing of compliance part of your company’s everyday business process.
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The end of Japan Inc.?
What happens when a series of scandals so engulfs a country that its entire national brand is put in jeopardy? Japan may have the answer.
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VW: The comeback begins
VW is currently demonstrating it can use a corporate scandal to wipe the corporate slate clean by refocusing on the emerging technologies for a greater business share.
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CCO learning from the KPMG indictments
There is no doubt KPMG was under pressure to improve the firm’s audit practices, but how much pressure does it take for three national practice leaders to actively participate in an illegal scheme? CCOs need to study this case and think about their firm’s regulatory oversight.
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The three levels of due diligence
How to recognize and utilize each level of due diligence to fight corruption.
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What is a root cause analysis?
The Justice Department has mandated a root cause analysis should be performed for every incident rising to the level of a compliance violation. Is your team ready to do so?
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The end of the compliance defense debate
Over the years, there has been a siren’s call for the addition of a compliance defense to the FCPA. It’s time to send the so-called “compliance defense” packing.
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South Africa sets up corruption commission
The Man From FCPA explores South African President Jacob Zuma’s intent to set up a nationwide corruption commission to look into allegations of rampant corruption through looting of government agencies and state-owned entities.
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Compliance and the immigration debate
The raids by ICE last week on 7-Eleven stores nationwide portend a good reason to document, document, document, and The Man From FCPA suggests you go back and double check your documentation at both your corporate headquarters and at each location, so if the government comes raiding, you will be ...
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Wells Fargo still suffering financially from scandals
Wells Fargo is one of the poster children over what can happen when compliance is not taken seriously or perhaps not at all in an organization.
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What is your investigation protocol?
If you follow this basic protocol from The Man From FCPA, you should be able to work through most investigations, in a clear, concise and cost-effective manner.
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Non-monetary and indirect cost of a FCPA investigation
The Man From FCPA recently spoke with Dan Chapman, CEO of Presyse Compliance, about his experience with the non-monetary costs and indirect costs of a major FCPA investigations.