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Day 17 Of One Month To Better Investigations and Reporting-Whom To Suspend During an Internal Investigation and De-Confliction

by Thomas Fox on

Who to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

Compliance into the Weeds-Episode 43, the Linde Declination

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the first Declination issued by the DOJ in the era of the Trump Administration, which was issued by the DOJ on June 16, 2017, when it issued a Declination to Linde North...more

Day 16 of One Month to Better Investigations and Report -Privacy Concerns in Investigation

by Thomas Fox on

Prior to the Schrems decision by the European Court of Justice, US based law firms could rely on Safe Harbor to use and analyze information from investigations conducted in Europe. However the Schrems decision and subsequent...more

FCPA Compliance Report-Episode 336, James Koukios on Morrison Foerster April Anti-Corruption Report

by Thomas Fox on

In this episode, James Koukios, a partner at Morrison & Foerster returns to discuss the firm's newsletter Top Ten International Anti-Corruption Developments for April 2017. In this episode we highlight the three following...more

Unfair and Unbalanced-Episode 20, Roy's Retirement Announcement Edition

by Thomas Fox on

In this episode, I visit with Roy Snell about his recent announcement that he is stepping down as head of the SCCE. We review the current state of the SCCE and how the Roy has seen the compliance evolve from its start after...more

Day 13 of One Month to Better Investigations and Reporting-The Yates Memo and Internal Investigations

by Thomas Fox on

When then Assistant Attorney General Sally Yates, announced the Memo that bears her name, she said the following, “we have revised our policy guidance to require that if a company wants any credit for cooperation, any credit...more

FCPA Compliance Report-Episode 335, Mike Volkov on Blockchain and Compliance

by Thomas Fox on

In this episode, Mike Volkov and I discuss how blockchain has the potential to transform compliance and may facilitate some truly revolutionary modifications in key businesses processes. I see some great value propositions...more

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

Blockchain Week in Review - June 2017 #5

by Perkins Coie on

Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more

Day 7 of One Month to Better Investigations and Reporting-How an Investigation Informs Remediation

by Thomas Fox on

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior management attention to the...more

This Week in FCPA-Episode 54, the Rubber Match Edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Blockchain and the financial markets: Will 2017 be the year of the regulators? New rules covering blockchain and distributed...

by White & Case LLP on

In 2016, policy makers and regulators started to take an active interest in blockchain and distributed ledger technology (DLT). However, many adopted a "wait and see" approach rather than producing binding regulations. 2017...more

Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforcement, business, PR and some...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Citigroup announced yesterday that it’ll pay nearly $100 million to resolve a long-running federal investigation into its Banamex USA group over lax money-laundering monitoring (largely for transfers between the US and...more

FCPA Compliance Report-Episode 326, Paula Long On The Intersection Of Data Security And Compliance

by Thomas Fox on

In this episode I caught up with Paula Long, founder and CEO of DataGravity, Inc. at the recently concluded Collision 2017 Conference. Paula has worked in the data and information space for over 30 years and now helps...more

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

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

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

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

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

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

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

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

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

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

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

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