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Compliance into the Weeds-Episode 50, Where's the Upside?

by Thomas Fox on

In this very topical episode Matt Kelly and I take a deep dive into the administration’s response to the events over the weekend in Charlottesville and what it means for business leaders, compliance practitioners and others...more

Day 12 of One Month to More Effective Continuous Improvement-Keeping Track of Current Events

by Thomas Fox on

In 2015, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to this...more

Day 13 of One Month to More Effective Continuous Improvement-Big Data and Continuous Monitoring

by Thomas Fox on

I continue my discussion of continuous improvement using big data in a best practices compliance program, with some thoughts on how to use it going forward. In an eBook, entitled “Planning for Big Data – A CIO’s Handbook to...more

Day 11 of One Month to More Effective Continuous Improvement-the Desktop Risk Assessment

by Thomas Fox on

Another mechanism to facilitate continuous improve comes from ideas around risk assessments. Both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) make clear the need for a risk assessment to...more

Leadership Lessons from Dunkirk

by Thomas Fox on

In this episode Richard Lummis and I consider the movie Dunkirk and the leadership lessons which can be drawn from the movie and historical events. If you have not seen it, I would suggest you go to see what I believe is the...more

Announcement Clarifies Regulatory Position on Digital Token Offerings in Singapore

by Jones Day on

In the wake of a recent increase in the number of initial coin (or token) offerings ("ICOs") in Singapore as a means of raising funds, as well as announcements from other concerned regulators, including in the United States,...more

Day 10 of One Month to More Effective Continuous Improvement-Controls Testing

by Thomas Fox on

Continuous improvement requires that you not only audit and monitor but also that you test your controls. In addition to the language set out in the 2012 FCPA Guidance, two of the seven compliance elements in the US...more

FCPA Compliance Report-Episode 345-Mike Volkov on Linde Gas and CDM Smith declinations

by Thomas Fox on

In this episode Mike Volkov and I discuss the two official pronouncements from the Sessions’ Justice Department regarding FCPA enforcement. They were both declinations used under the FCPA Pilot Program, which was announced in...more

Day 9 of One Month to More Effective Continuous Improvement-the Fraud Audit

by Thomas Fox on

Today I consider a fraud audit by using data analytics to help detect or prevent bribery and corruption where the primary sales force used by a company are its FCPA and Chinese domestic law, involved China based employees...more

Compliance into the Weeds-Episode 49, Mattis Memo on Ethics

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the weeds on a Memo issued by Secretary of Defense James Mattis last week. It deals specifically with ethical conduct within the DOD and US military. It is one of the...more

Day 7 of One Month to More Effective Continuous Improvement-the Supply Chain Audit

by Thomas Fox on

In my last corporate position, my company was at the cutting edge because we required compliance related audits for vendors in the supply chain. This was cutting edge in 2007-08. However, now an audit for adherence to...more

Day 6 of One Month to More Effective Continuous Improvement-Data Analytics and the Monitoring of Third Parties

by Thomas Fox on

Next I consider at how data analytics can be used for continuous improvement where the primary sales force used by a company is third parties. A clear majority of Foreign Corrupt Practices Act (FCPA) violations and related...more

Day 5 of One Month to More Effective Continuous Improvement-Auditing of Third Parties

by Thomas Fox on

Third parties still present the highest risk around FCPA compliance. It is therefore critical that you use monitoring and auditing when it comes to continuous improvement for this high-risk area. Today I want to consider...more

Compliance Report-International Edition-Tim Khasanov on Compliance in post Soviet states

by Thomas Fox on

In this episode, I visit with Timur Khasanov-Batirov. Tim is a compliance practitioner with focus at high-risk markets and author of practical guide “Integrity Corp. 50 Tips for Your Compliance Program in the Post-Soviet...more

This Week in FCPA-Episode 64, the 10-Year Anniversary Edition

by Thomas Fox on

Show Notes for This Week in FCPA-Episode 64, for the week ending August 4, the 10 Year Anniversary Edition   In this special Saturday edition, Jay and I return for a wide-ranging discussion on some of the week’s top...more

Day 4 of One Month to More Effective Continuous Improvement-Process for Continuous Controls Monitoring

by Thomas Fox on

Most Chief Compliance Officers (CCOs) and compliance practitioners understand the need for continuous controls monitoring. Whether it be as a part of your overall monitoring of third parties, employees, or to test the overall...more

Day 2 of One Month to More Effective Continuous Improvement-the Compliance Audit

by Thomas Fox on

Interestingly, Foreign Corrupt Practices Act (FCPA) compliance in many ways follows some of the paths laid out by corporate safety departments some 20-30 years ago when safety became much more high profile in US corporations....more

COMPLIANCE INTO THE WEEDS-EPISODE 48-THE HALLIBURTON FCPA ENFORCEMENT ACTION

by Thomas Fox on

In this episode, Matt Kelly and I explore last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton...more

Corporate and Financial Weekly Digest - Volume XII, Issue 29

BROKER-DEALER - SEC Cautions Securities Laws May Apply to Interests in Virtual Organizations - On July 25, the Securities and Exchange Commission issued a Report of Investigation cautioning that certain offers and sales...more

Day 1 of One Month to More Effective Continuous Improvement-Continuous Improvement in a Compliance Program

by Thomas Fox on

Welcome to the August edition of One Month to More Effective Continuous Improvement. As you know, each month in 2017 I am presenting a series of podcasts on one topic which will allow you to create a more effective compliance...more

12 O'Clock High-Margaret Johnson, taking your leadership from SOS to WOW

by Thomas Fox on

In this episode, I visit with Margaret Johnson, the author of the book From SOS to WOW. This book can help you to move your leadership skills to a new level by helping you bust through assumptions, unleash your creative ideas...more

Germany tightens restrictions on foreign investment from outside the EU

by Dentons on

On July 18, 2017, Germany passed an amendment to its foreign investment regime that will make acquisitions of German companies by foreign acquirers considerably more time consuming and potentially more complex. Chinese...more

Day 22 of One -Lessons in Failures of Internal Controls

by Thomas Fox on

I conclude this one month series by considering the recently concluded Securities and Exchange Commission (SEC) resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company. I...more

FCPA Compliance Report-Episode 344, Virginia Suveiu

by Thomas Fox on

In this episode, I visit with Virginia Suveiu who counsels on legal risk management, regulatory compliance and public policy, as well as commercial and international law matters. We discuss the wide variety of risks that...more

Day 21 of One Month to More Effective Internal Controls-Revenue Recognition, Internal Controls and Compliance

by Thomas Fox on

In May 2014, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers. The amendments become effective for public entities for annual reporting...more

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