Thomas Fox – Advanced Compliance Solutions

FCPA Compliance and Ethics Report-Episode 262-the Brexit Edition, with Jonathan Armstrong [Video]

In this special Brexit episode, I visit with UK lawyer Jonathan Armstrong about the potential impacts of the British exit from the EU for the FCPA compliance practitioner around issues relating to data privacy and data transfer…more
| Business Organizations, Finance & Banking, International Law & Trade, Law Practice Products & Services, Science, Computers, & Technology

Battle of the Somme Week – Part I: The Analogic FCPA Enforcement Action

I have not written much in honor of the centennial of the First World War (WWI). However this week I will to remedy this oversight by focusing on the Battle of the Somme, leading up to the first day of the long battle, which…more
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Unfair and Unbalanced-the Victimization Episode [Video]

In this episode Roy Snell and I discuss: Victimization and the value of personal responsibility; Standing up for your principles; The idea that you can make your sales goals without breaking the law; Roy translates wink…more
| Business Organizations, Elections & Politics, Mergers & Acquisitions, Privacy, Science, Computers, & Technology

Compliance Training – Part IV: the Gamification of Compliance Training

I conclude my four-part series on ethics and compliance training today by looking where effective training is going. One of the criticisms leveled by L. V. Anderson, in her Slate article, entitled “Ethics Trainings Are Even…more
| Commercial Law & Contracts

Compliance Training – Part III: Effectiveness and Evaluation

This week, I am exploring issues related to compliance and ethics training, inspired by an article in the online publication, Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by author L.V. Anderson. Today I…more
| Commercial Law & Contracts, International Law & Trade

Compliance Training – Part II: Risk Ranking and Design

Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and assess…more
| Commercial Law & Contracts, International Law & Trade

Compliance into the Weeds-Episode 9-the COSO ERM Framework  [Video]

In this episode Matt Kelly and I go deep into the weeds to being our discussion of the new COSO Enterprise Risk Management Framework…more
| Business Organizations, Commercial Law & Contracts, Finance & Banking, Science, Computers, & Technology, Securities Law

FCPA Compliance and Ethics Report-Episode 260-Designing and Implementing Effective Compliance Training [Video]

In this episode I discuss how to design, implement and evaluate effective compliance training…more
| Commercial Law & Contracts, Communications & Media Law, Education, International Law & Trade, Science, Computers, & Technology

Compliance Training, Part I

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees but…more
| Commercial Law & Contracts, International Law & Trade

Goldman Trial in London – See Any FCPA Issues?

It has been known for some time that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have been investigating investment banks over their dealings with the Libyan sovereign wealth fund, known as the…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law

This Week in FCPA-Episod 9 [Video]

In this episode Jay Rosen and I discuss the FCPA related events for the week of June 17. We talk about the Biomet DPA extension, the Rincon FCPA guilty plea, open FCPA investigations in China and the recently concluded ACFE…more
| Business Organizations, Education, International Law & Trade, Science, Computers, & Technology, Securities Law

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out in…more
| Civil Procedure, Commercial Law & Contracts, Finance & Banking, International Law & Trade

Unfair and Unbalanced-Episode 8 [Video]

In this episode, Roy Snell and I continue to explore issues around the compliance profession and compliance professionals…more
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Law Practice Products & Services, Science, Computers, & Technology

Good-Bye to Mr. Hockey and Curiosity in a CCO

Gordon ‘Gordie’ Howe died last week. To most of North America he was simply known as “Mr. Hockey”. In his first hockey career, he played in a by-gone era of what we now call the ‘Original 6’ where two Canadian teams and four…more
| Commercial Law & Contracts

The Damaging Myth of the Rogue Employee

As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives are…more
| Commercial Law & Contracts, Labor & Employment Law, International Law & Trade
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