Thomas Fox – Advanced Compliance Solutions

ThisWeek in FCPA-Episode 14, the Wolf of Wall Street Edition [Video]

In this episode, Jay Rosen and I talk about the SFO investigation into Unaoil, the forfeiture lawsuit filed in the 1MDB scandal, the possible JP MorganChase sons and daughters FCPA settlement, the new Standard Law School FCPA…more
| Art, Entertainment, & Sports Law, Business Organizations, Finance & Banking, Science, Computers, & Technology, Securities Law

Enforcement Week V: Three-Month Pilot Program Wrap Up

Today, I end my exploration of recent Foreign Corrupt Practices Act (FCPA) enforcement actions (and one UK Bribery Act enforcement issue), which have occurred since the enactment of the Department of Justice (DOJ) Pilot Program…more
| Commercial Law & Contracts, International Law & Trade

Enforcement Week IV: The XYZ Deferred Prosecution Agreement in the UK

I continue my exploration of anti-corruption enforcement with a slight detour across the pond to visit the recent Deferred Prosecution Agreement (DPA) awarded in the UK Crown Court at Southwark, entitled Redacted Approved…more
| Commercial Law & Contracts, International Law & Trade

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 268-leadership lessons from Brexit [Video]

In this episode, Richard Lummis and I visit on the leadership failures and lessons to be learned from the Brexit vote and its aftermath…more
| Antitrust & Trade Regulation, Constitutional Law, Environmental Law, International Law & Trade, Science, Computers, & Technology

Enforcement Week II: The Johnson Controls FCPA Enforcement Action – Part I

I continue my exploration of recent enforcement matters and issues by turning to the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action, which was announced last week. Mike Volkov has called the…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Enforcement Week I: Troubling Questions Raised in HSBC Prosecution

We had an interesting week of anti-corruption enforcement actions last week, both in the US and the UK. We have now had four Foreign Corrupt Practices Act (FCPA) enforcement actions since the announcement of the Depart Of…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

Innovation in Compliance Week – Part V: The Innovation Process

I have been exploring innovation in the compliance function this week. For my final piece I want to consider the innovation process itself. In an article in the MIT Sloan Management Review, entitled “Finding a Lower-Risk Path to…more
| Commercial Law & Contracts, International Law & Trade

Innovation in Compliance Week- Part IV: Innovation Through Continuous Improvement

What is the intersection of innovation in your compliance program and the requirements of an effective compliance program? I find the answer to be found in Hallmark 10 of the Ten Hallmarks of an Effective Compliance Program set…more
| Commercial Law & Contracts, International Law & Trade

Innovation in Compliance – Part III: Design Thinking

I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not only…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 266, Ben Locwin on people v. systems approach to compliance programs [Video]

In this episode, I visit with Ben Locwin on the different approaches in compliance around people v. systems…more
| Business Organizations, Commercial Law & Contracts, Environmental Law, Health, Science, Computers, & Technology

What is non-GAAP? [Video]

What is non-GAAP?…more
| Business Organizations, Securities Law

Innovation in Compliance Week, Part II-Superforecasting

I continue my Innovation in Compliance series today by discussing “superforecasting” and its use by a compliance function. Imagine that as a Chief Compliance Officer (CCO), you could create a team which might well dramatically…more
| Commercial Law & Contracts

Innovation in Compliance Week – Part I: Embracing Agile

This week I begin a five-part series on innovation in the compliance function. One of the most constant things that I have observed in my nearly 10 years of practice in the compliance space is its constant evolution. Compliance…more
| Commercial Law & Contracts

This Week in FCPA-Episode 12 [Video]

In this episode, Jay Rosen and myself take a look at the line drawn from the Yates Memo to the hiring of Hui Chen, to the Pilot Program, the 3 enforcement actions since then and conclude that FCPA enforcement is changing. Jay…more
| Business Organizations, Criminal Law, Law Practice Products & Services, Science, Computers, & Technology, Securities Law
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