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Day 19 of One Month to 3rd Party Management-Risk Ranking in the Supply Chain [Video]

by Thomas Fox on

One of the areas many companies do not focus on enough is possible corruption in their Supply Chain (SC) for goods and services provided on a company’s behalf. The FCPA risks can be just as great through those entry points as...more

Day 18 of One Month to 3rd Party Management-Freight Forwarders [Video]

by Thomas Fox on

The FCPA world is littered with cases involving freight forwarders, brokers and agents in the shipping and express delivery arena. Both the Department of Justice and Securities and Exchange Commission have aggressively...more

Day 17 of One Month to 3rd Party Management-Distributor Compensation [Video]

by Thomas Fox on

One of the issues in any compliance program is the compensation paid to a third party as FCPA exposure arises when companies pay money - either directly or indirectly - to fund bribe payments. In the traditional intermediary...more

Day 16 of One Month to 3rd Party Management-Terminating a Third Party [Video]

by Thomas Fox on

At some point, you will be required to terminate a third-party and there will be multiple legal, compliance and business issues to navigate going forward. If you are stuck doing it in the middle of a Foreign Corrupt Practices...more

Compliance into the Weeds-Episode 36, McFadden Remarks on FCPA Enforcement [Video]

by Thomas Fox on

In this episode, Matt Kelly and I take a very deep dive into two recent speeches by Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden in which he addressed multiple topics and issues...more

Day 15 of One Month to 3rd Party Management-Third Party Management ROI [Video]

by Thomas Fox on

One area that has bedeviled Chief Compliance Officers (CCOs) and compliance practitioners is how to determine the return on investment (ROI) for your compliance program regarding third parties. While it is still clear that...more

Day 14 of One Month to Better 3rd Party Management-Third Party Program Check Up [Video]

by Thomas Fox on

When was the last time you gave your third party risk management program a check up?...more

Day 14 of 30 Days to a Better 3rd Party Management-Third Party Program Check Up [Video]

by Thomas Fox on

When was the last time you considered the health of your company’s third party management program? A good way to test that well-being is to perform a check-up on your third party program....more

Day 13 of One Month to Better 3rd Party Management-Internal Controls for Third Parties [Video]

by Thomas Fox on

Internal controls are a key tool to operationalize your third party risk management program. Initially, a compliance practitioner should perform an analysis of any third party representative to provide insight into the...more

FCPA Compliance Report-International Edition, the Prague Report [Video]

by Thomas Fox on

In this episode I am joined by Ruth Steinholtz of AretéWork, Jonathan Armstrong of Cordery Compliance and Kristy Grant-Hart of Spark Compliance Consulting and author of How To Be a Wildly Effective Compliance Officer for a...more

FCPA Compliance Report-Episode 323-Bill Coffin on Compliance Week 2017 [Video]

by Thomas Fox on

In this episode Compliance Week Editor in Chief Bill Coffin discusses the upcoming Compliance Week 2017 Conference May 22-24, 2017 in Washington DC. Coffin highlights the key note speakers and some of the other key topics for...more

Day 12 of One Month to Better 3rd Party Management-Data Analytics and Ongoing Monitoring of Third Parties [Video]

by Thomas Fox on

Next I consider at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force used by a company is third parties. A clear majority of Foreign Corrupt Practices Act (FCPA)...more

Day 11 of One Month to Better 3rd Party Management-Auditing Third Parties [Video]

by Thomas Fox on

Auditing of third parties is critical to any best practices compliance program and an important tool in operationalizing your compliance program. This is a key manner in which a company can manage the third party relationship...more

This Week in FCPA-Episode 48, CEOs Behaving Badly edition [Video]

by Thomas Fox on

In this episode, Matt Kelly pinch hits for a Walt Disney World-vacationing Jay Rosen. Matt and I have a wide-ranging discussion on some of the week’s top FCPA and compliance related stories. We discuss: 1. Shearman &...more

Day 10 of One Month to Better 3rd Party Management-Managing Your Third Parties [Video]

by Thomas Fox on

The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program. For instance in the lifecycle management of third parties, most...more

FinTech – The CFTC’s Silver Bullet?

by King & Spalding on

On March 15, Acting US Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo excited the futures and options markets when he spoke at length about embracing technology as a key to economic growth. ...more

Day 9 of One Month to Better 3rd Party Management-DOJ Metrics On Third Party Management  [Video]

by Thomas Fox on

In a speech before the SIFMA Compliance and Legal Society New York Regional Seminar in November 2015, then Assistant Attorney General Leslie Caldwell laid out metrics the Department of Justice would consider in evaluating a...more

Compliance into the Weeds-Episode 35, PCAOB Report on Emerging Growth Companies [Video]

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the recently released, Public Company Accounting Oversight Board (PCAOB) semi-annual white paper. The white paper provided general information about characteristics of...more

FCPA Compliance Report-Episode 322-Eric Feldman on Pro-active use of monitors [Video]

by Thomas Fox on

In this episode, I am joined by Eric Feldman, SVP at Affiliated Monitors. Eric is a long time US government employee who now helps to provide companies with monitorship services, in a wide range of areas. These include...more

Day 7 of One Month to Better 3rd Party Management-Levels of Due Diligence [Video]

by Thomas Fox on

The Justice Department Evaluation of Corporate Compliance Programs states in Prong 10,   Appropriate Controls – What was the business rationale for the use of the third parties in question? What mechanisms have existed to...more

This Week in FCPA-Episode 47-the Season Opener Edition [Video]

by Thomas Fox on

Show Notes for Episode 47, for the week ending April 7, the Season Opener Edition   In this episode, Jay and I have a wide-ranging discussion on some of the week’s top FCPA and compliance related stories. We discuss: 1....more

Day 5 of One Month to Better 3rd Party Management-Levels of Due Diligence [Video]

by Thomas Fox on

Yesterday I considered the need for due diligence in the management of third parties. Today, I want to take a deeper dive and explore the levels of due diligence. Due diligence is generally recognized in three levels: Level...more

FCPA Compliance Report-Episode 321-Adelle Elia, Chief Integrity Officer at Louis Berger [Video]

by Thomas Fox on

In this episode I visit with Adelle Elia, the Chief Integrity Officer at Louis Berger. Some of the highlights include: Why is her title “Chief Integrity Officer” as opposed to Chief Compliance Officer or Chief Ethics and...more

Compliance into the Weeds-Episode 34 [Video]

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the recent kerfuffle involving United Airlines and its policy which prevented to teenaged girls from boarding a flight wearing leggings. Was United within its rights to...more

Day 3 of One Month to Better 3rd Party Management-the Questionnaire [Video]

by Thomas Fox on

The next step in the five-step process is the Questionnaire. The term ‘questionnaire’ is mentioned several times in the 2012 FCPA Guidance. It is generally recognized as one of the tools that a company should complete in its...more

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