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Everything Compliance-Episode 14

by Thomas Fox on

We mix up things this week as the panelists' suggest the topics. Topics from Matt: 1. Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a tough...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

In Case You Missed It: Launch Links - July, 2017 #2

by WilmerHale on

Some interesting links we found across the web this week: Why It’s so Difficult to Disrupt - The growing expectations of venture capitalists may be pushing founders to focus solely on unsustainable growth, rather than...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

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

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

Delaware’s Blockchain Initiative to Revolutionize the Stock Trade

by Goodwin on

With the near unanimous passing of a bill that will explicitly recognize the right to trade stocks using a blockchain, Delaware is making a strong case for it being the blockchain-friendliest state. The Delaware Senate...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

Day 2 of One Month to More Effective Internal Controls

by Thomas Fox on

Today, New York Times columnist David Brooks’ thoughts on building and maintaining order inform our discussion on internal controls. In the area of internal controls, I believe it is incumbent to consider not only the most...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

This Week in FCPA-Episode 59, the Holiday Edition

by Thomas Fox on

In this week which starts the 4th of July holiday weekend, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The second Declination of the Session’s Justice...more

Day 22 of One Month to Better Investigations and Reporting-Building Employee Trust in Your Reporting Mechanism

by Thomas Fox on

Yesterday I considered an article by Ryan Hubbs, entitled “10 Factors Leading to Reporting Mechanism Distrust”, in which he detailed 10 factors leading to hotline distrust. Today I want to pick up on that article with Hobbs'...more

Day 21 of One Month to Better Investigations and Reporting-Factors Leading to Hotline Distrust

by Thomas Fox on

The guidance and mandates for companies on reporting mechanism reporting are numerous, overlapping and sometimes very broad. There are the US Sentencing Guidelines; regulations under Sarbanes-Oxley (SOX), the Dodd-Frank Act...more

Everything Compliance-Episode 13

by Thomas Fox on

The top compliance roundtable podcast is back with a wealth of new topics. Stayed tuned to the end where there are some heartfelt and somber rants in this edition. 1. Matt Kelly opens with a discussion on Uber from the...more

Compliance into the Weeds-the Compliance Profession and the Cannabis Industry

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive, literally into the weeds of the convergence of the compliance profession and the nascent cannabis industry. While several states have made pot for medical use legal and one...more

Day 20 of One Month to Better Investigations and Reporting-Staying Out of Hot Water in Other Jurisdictions

by Thomas Fox on

In an article entitled “How to Launch and Operate a Legally-Compliant International Workplace Report Channel” or in compliance parlance, a hotline, author Donald Dowling of the law firm of White and Case, provided a useful...more

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