Thomas Fox – Compliance Evangelist

Day 23 of 30 Days to a Better Compliance Program-Answering Questions [Video]

I often write about the nuts and bolts of an effective compliance program but one of the most basic things that an effective compliance program must have is a compliance department present to ask the basic questions of…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Rolls-Royce Global Enforcement Action: Part IV – What Does it all Mean?

Today I conclude my series on the Rolls-Royce global anti-corruption enforcement action by taking a look what it all means going forward. The resolution is more than simply the stunning fines and penalties of £671 million (more…more
| Commercial Law & Contracts, International Law & Trade

Day 22 of 30 Days to a Better Compliance Program-the Regional Compliance Committee [Video]

Earlier I considered the Compliance Oversight Committee. Today, I want to you to consider another compliance committee which could positively impact your compliance regime, the Regional Compliance Committee which is created at…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 21 of 30 Days to a Better Compliance Program-the Board of Directors Compliance Committee [Video]

The Compliance Oversight Committee sits between the CCO and the Board’s compliance committee. The role of this Compliance Oversight Committee is to provide oversight and review of items such as third party approvals and…more
| Business Organizations, Finance & Banking, International Law & Trade, Securities Law

This Week in FCPA-Episode 36-Jeff Bagwell in the Hall of Fame edition [Video]

Show Notes for Episode 36, week ending January 20, the Jeff Bagwell in the Hall of Fame edition: 1. Jeff Bagwell admitted into the Hall of Fame. 2. Rolls Royce-stunning $800MM global settlement, including resolutions with the…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology

Rolls Royce Global Enforcement Action-Part III, the US DPA

Today I continue my exploration of the Rolls-Royce global corruption enforcement action by considering the company’s resolution in the US under the Foreign Corrupt Practices Act (FCPA). Before we dive into that, I first…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade

Day 20 of 30 Days to a Better Compliance Program-the Board of Directors Compliance Committee [Video]

Under the US Sentencing Guidelines, the Board must exercise reasonable oversight on the effectiveness of a company’s compliance program. The US Department of Justice (DOJ) Prosecution Standards posed the following queries: (1)…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 19 of 30 Days to a Better Compliance Program-Compliance Expertise on the Board [Video]

Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 18 of 30 Days to a Better Compliance Program-Email Sweeps [Video]

Ongoing monitoring is not limited to the financial component of compliance. The concept is straightforward; at regular intervals you can sweep through your company email database for identified key words that can be flagged for…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Everything Compliance-Episode 5, year-end wrap up Part II [Video]

We turn to the 2016 year in review, in this Part II of a two-part series. Jonathan Armstrong leads a discussion on Privacy Shield, information and data privacy issues the past year. Mike Volkov relates what he saw as the top…more
| Criminal Law, Finance & Banking, Labor & Employment Law, Science, Computers, & Technology, Securities Law

Rolls-Royce Global Enforcement Action, Part II

Today I continue my exploration of the Rolls-Royce global corruption enforcement action which included the largest fine to-date under the UK Bribery Act, with its total fines and penalties under three agreements being around…more
| Commercial Law & Contracts, International Law & Trade

Day 17 of 30 Days to a Better Compliance Program-Uncovering Shell Companies [Video]

One of the more prescient authors I know is Ryan C. Hubbs, who in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. Shell companies can come in different shapes and sizes. Shelf companies are those formed but not…more
| Business Organizations, Finance & Banking, International Law & Trade, Real Estate - Residential, Science, Computers, & Technology

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years later,…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade

Compliance into the Weeds-Episode 25 [Video]

In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and the continued issues around…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Recidivism Under the FCPA: Zimmer Biomet

Last week Zimmer Biomet Holdings, Inc. paid a high price for its and its predecessors failure to comply with the terms and conditions of 2012 Deferred Prosecution Agreement (the “2012 DPA”). Biomet, having originally paid $23…more
| Commercial Law & Contracts, International Law & Trade, Securities Law
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