Thomas Fox – Compliance Evangelist

I Believe in Father Christmas and Internal Controls for Gifts in the Holiday Season

Rock and roll heaven got another power player this week as Greg Lake died on December 7th. He was one-third of the greatest prog rock trio Emerson, Lake & Palmer (aka ELP). With apologies to Patrick Hays and all you Rush-heads…more
| Commercial Law & Contracts, International Law & Trade

How the Yellow Submarine Informs Due Diligence Lessons From 1MDB

Enrichment is the theme for today’s post as it is personal and illegal enrichment which seems to be the continuing message from the 1MDB scandal involving the disgraced Malaysian sovereign wealth fund. In an article in the Wall…more
| Commercial Law & Contracts, International Law & Trade

Everything Compliance-Episode 3 [Video]

We are back to our more rounded format for this episode on a variety of topics including anti-corruption enforcement across the globe, the new French anti-corruption law, Sapin II, the Agricultural Bank of China compliance…more
| Business Organizations, Criminal Law, International Law & Trade, Science, Computers, & Technology, Securities Law

The Chairman’s Flight and the US Corrupt Practices Act

Earlier this week a most interesting non-Foreign Corrupt Practices Act (FCPA) bribery and corruption enforcement, actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit…more
| Commercial Law & Contracts, Securities Law, Transportation

Compliance into the Weeds-Episode 21-the DOJ and Congressional Legislation in the Trump Era [Video]

In this episode, Matt Kelly and I take a deep dive into two areas which will impact compliance practitioners going forward. They are the Justice Department under the Trump Administration and the legislative process going…more
| Business Organizations, Mergers & Acquisitions, International Law & Trade, Science, Computers, & Technology, Securities Law

For the Corporate Compliance Department – Communicate, Communicate, then Communicate

In many ways compliance is about communication. Your role as a Chief Compliance Officer (CCO) or compliance practitioner is to communicate expectations around compliance and responding to questions from the business unit on how…more
| Commercial Law & Contracts

FCPA Compliance Report-Episode 293, Saskia Zandieh on the new French Anti-Corruption law, Sapin II [Video]

In this episode, I visit with Miller & Chevalier Counsel, Saskia Zandieh on the new French anti-corruption law, Sapin II. She discusses how it may improve the nation’s current anti-corruption framework, and reviews the practical…more
| Business Organizations, Mergers & Acquisitions, International Law & Trade, Science, Computers, & Technology, Securities Law

This Week in FCPA-Episode 31, the Government Speaks edition [Video]

Show Notes for Episode 31, week ending December 2, 2016-the Government Speaks edition 1. Justice Department Assistant Attorney General Sally Yates remarks at 33rd annual ACI National FCPA Conference; 2. Head of SEC…more
| Business Organizations, Finance & Banking, International Law & Trade, Mergers & Acquisitions, Science, Computers, & Technology, Securities Law

Forecasting, Risk Management and Compliance

When I was in the corporate world, I cannot begin to recall the number of times senior management had an overly optimistic forecast regarding some transaction; whether the transaction was the purchase of a smaller company, a…more
| Commercial Law & Contracts, International Law & Trade

Anti-Corruption Enforcement Has Gone International

Matt Stephenson, myself and others have engaged in a dialogue about where Foreign Corrupt Practices Act (FCPA) enforcement may be headed under the incoming administration. I have tried to focus on why compliance with…more
| Commercial Law & Contracts, International Law & Trade

Compliance into the Weeds-Episode 20-transaction monitoring [Video]

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company personnel…more
| Finance & Banking, International Law & Trade, Mergers & Acquisitions, Science, Computers, & Technology, Securities Law

Email Sweeps- A New Approach to Ongoing Monitoring

The FCPA Guidance specifies that “a good compliance program should constantly evolve. A company’s business changes over time, as do the environments in which it operates, the nature of its custom­ers, the laws that govern its…more
| Commercial Law & Contracts, International Law & Trade

On Leadership – A Simple Message and Asking the Right Questions

Sometimes, as a leader it is important to say something numerous times, to repeat your message so that it will come through loud and clear. For any Chief Executive Officer (CEO) it is incumbent to continually reinforce your…more
| Commercial Law & Contracts

FCPA Compliance Report-Episode 292-Jared Connors on FARs and DFARs [Video]

In this episode Jared Connors and I discuss: 1. What is a FAR? 2. What’s the differences with DFARs? 3. What types of companies should be concerned? 4. What are some examples of covered with these regulations? 5. What are…more
| Commercial Law & Contracts, Energy & Utilities, Government Contracting, International Law & Trade, Science, Computers, & Technology

Spikes in Sales and Compliance

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company personnel…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade
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