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FCPA Compliance Report-Episode 343, James Koukios on Morrison Foerster May Anti-Corruption Report

by Thomas Fox on

In this episode I visit with James Koukios, a partner at Morrison and Foerster on the firm’s newsletter, Top Ten International Anti-Corruption Developments for May 2017. Our topics include: 1. FCPA Assistant Chief BJ...more

Day 15 of One Month to More Effective Internal Controls-COSO’s Objectives and Principles: Control Environment

by Thomas Fox on

The updated Framework retained the core definition of internal controls; those being control environment, risk assessment, control activities, information and communication, and monitoring activities. However, it built up...more

Day 13 of One Month to More Effective Internal Controls-Code of Conduct as an Internal Control

by Thomas Fox on

Last year, one of the most interesting non-Foreign Corrupt Practices Act (FCPA) enforcement actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit paid out by United...more

Everything Compliance-Episode 14

by Thomas Fox on

Show Notes for Everything Compliance-Episode 14 Topics from Matt: 1.Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a tough Trump Admin...more

Day 12 of One Month to More Effective Internal Controls-Board Oversight as an Internal Control

by Thomas Fox on

Is a Board of Directors a compliance internal control? I think the clear answer is yes. In the FCPA Guidance, in the Ten Hallmarks of an Effective Compliance Program, there are two specific references to the obligations of a...more

COMPLIANCE INTO THE WEEDS-EPISODE 46-THE POTTED PLANT EDITION

by Thomas Fox on

In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s report in the HSBC...more

Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment

by Thomas Fox on

It is reasonable to expect that internal controls over gifts, travel and entertainment (GTE) be designed to ensure that all satisfy the criteria as defined in company policies. Generally speaking, these are fairly narrow,...more

[Webinar] Venue and Exhaustion: Practical Effects of TC Heartland and Lexmark - July 26th, 10:00 am China, CST

The U.S. Supreme Court recently issued highly anticipated opinions in two patent cases, both of which may have a profound impact internationally....more

The Impact of the General Data Protection Regulation on Responses to Data Breaches Involving EU Personal Data

by McDermott Will & Emery on

The forthcoming General Data Protection Regulation will expand the legal obligations of companies that process EU personal data when they suffer a data breach. Every company faces the risk of a data breach that might trigger...more

FCPA Compliance Report-Episode 342, Melanie Johnson

by Thomas Fox on

In this episode, I visit with Melanie Johnson, co-founder of Elite Online Publishing, which aids entrepreneurs, business leaders, and professional athletes to create, publish, and market their books, to build their business...more

Day 9 of One Month to More Effective Internal Controls-Mapping Your Compliance Internal Controls

by Thomas Fox on

As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The BHP enforcement continued...more

This Week in FCPA-Episode 61, for the week ending July 14, the Summer in the City Edition

by Thomas Fox on

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: 1. HSBC monitor report protected from release. 2. The Odebrecht scandal continues to...more

Opportunity Foreclosed: The International Entrepreneur Parole Rule May Die Before it Gets Out of the Gate

The U.S. and worldwide entrepreneur community had been looking forward to July 17th with great anticipation. This was supposed to be the effective date of the new International Entrepreneur Parole immigration regulation....more

Day 8 of One Month to More Effective Internal Controls-What is a Gap Analysis?

by Thomas Fox on

A gap analysis is a method of assessing the differences in performance between a business' internal controls to determine whether business requirements are being met and, if not, what steps should be taken to ensure they are...more

Compliance Report-International Edition-Carlos Ayers on Tropicalizing Your Compliance Program

by Thomas Fox on

In this episode I visit with Carlos Ayers on steps you can take to make your compliance program more effective to employees in Latin America. This includes such things are localizing your training and presentations,...more

Day 7 of One Month to More Effective Internal Controls-Implementing Internal Controls

by Thomas Fox on

Today, I consider some ways in which a compliance professional can work to implement internal controls in a multi-national organization. The first step is to convert your company’s compliance risks into internal control...more

Day 5 of One Month to More Effective Internal Controls-Assessing for Internal Controls in International Operations

by Thomas Fox on

Today, I want to discuss how to assess for your internal controls regime for international operations. It is incumbent that you need to review as much information so you can to understand the financial and operational...more

COMPLIANCE INTO THE WEEDS-EPISODE 45, THE UNDESERVED PRIVILEGE EDITION

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the 4th of July weekend use of the New Jersey beaches by Governor Chris Christie. Governor Christie had closed the beaches in a budget dispute but was still able, as...more

Day 4 of One Month to More Effective Internal Controls-Internal Controls in International Locations

by Thomas Fox on

Next, I want to consider some of the issues around internal controls outside the US and why your company’s internal controls might require changes for different countries across the globe. However, this provides an...more

FCPA Compliance Report-Episode 341, Brian Alster on the Problem of Beneficial Ownership

by Thomas Fox on

The issue of beneficial ownership is one which still bedevils many compliance professionals. Today, I visit with Brian Alster, Dun & Bradstreet’s Global Head of Supply and Compliance about the problem this issue continues to...more

This Week in FCPA-Episode 60, the All-Star Weekend Edition

by Thomas Fox on

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including:   1. U.S. charges top Colombia anti-graft prosecutor with money laundering. 2. US Supreme Court may...more

Day 3-The Four Key Internal Controls for Compliance

by Thomas Fox on

There are four significant controls that I would suggest the compliance practitioner implement initially. They are: (1) Delegation of Authority (DOA); (2) Maintenance of the vendor master file; (3) Contracts with third...more

FCPA COMPLIANCE REPORT-EPISODE 340, PATRICK HENZ, AUTHOR OF ACCESS GRANTED

by Thomas Fox on

In this episode, I visit with Patrick Henz, a compliance practitioner and author of Access Granted: Tomorrow’s Business Ethics. Henz has written one of the most fascinating books on compliance going forward into the future...more

FCPA COMPLIANCE REPORT-EPISODE 339, ED BUTHUSIEM OF BRG ON THE BUSINESS TRANSFORMATION OF COMPLIANCE

by Thomas Fox on

In this episode, I visit with Ed Buthusiem, with BRG Business Transformation. BRG partners with companies and their stakeholders to deliver sustainable results with speed and transparency through a data-driven and expert-led...more

In Case You Missed It: Launch Links - June, 2017 #4

by WilmerHale on

Some interesting links we found across the web this week: What the Global Marketplace Can Teach US Entrepreneurs About the Future of Payments - Entrepreneurs already have a lot going on, but it pays to be on top of the...more

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