Thomas Fox – Compliance Evangelist

First ‘Trial of the Century’ and the SQM FCPA Enforcement Action – Part II

Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance Report-Episode 308-Ben Locwin on Forecasting  [Video]

In this first part of a three part series on the risk management process, noted risk management guru Ben Locwin and I visit about forecasting in the risk management process…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 16 of One Month to a Better Board-the Board and Succession Planning [Video]

Yesterday, I considered the Board of Director’s role in hiring of senior executives and in other key positions and corporate positions and corporate relationships. Today I want to consider the Board’s role in succession…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

The Embraer FCPA Enforcement Action

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA (Embraer)…more
| Antitrust & Trade Regulation, Business Organizations, Commercial Law & Contracts, Government Contracting, International Law & Trade

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of questions…more
| Commercial Law & Contracts, Mergers & Acquisitions, International Law & Trade

Day 15 of One Month to a Better Board-the Board Role in Hiring [Video]

What is the role of a Board of Directors in hiring senior executives, Chief Compliance Officers and even other Board members? I recently explored this issue with Candice Tal, founder and CEO of Infortal, a global security and…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 14 of One Month to a Better Board-Boards and Doing Business in China [Video]

The bribery and corruption case of GlaxoSmithKline PLC (GSK) resonated across the corporate globe. While many questions are still unanswered, one that seems to be at the forefront of the inquiry was where was the GSK Board of…more
| Business Torts, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of…more
| Commercial Law & Contracts, International Law & Trade

This Week in FCPA-Episode 40- the Worse than Useless edition [Video]

Just out the week's top compliance and ethics stories on This Week in FCPA…more
| Business Organizations, Finance & Banking, Science, Computers, & Technology, Securities Law

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Day 13 of One Month to a Better Board-Board Failures in Compliance [Video]

The failure of a Board of Directors to engage in its duties and obligations around the compliance function can be devastating. Today I consider cases where Boards failed in those duties…more
| Business Organizations, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 12 of One Month to a Better Board-What Leads to a Successful Board Investigation [Video]

What are metrics for a Board around compliance? Former Assistant Attorney General Leslie Caldwell laid out some that the Justice Department would consider in a review of compliance programs. These metrics are: ¥ Does the…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

ENI Receives ISO 37001 Certification and ENI CEO Charged with Corruption

Today’s headline is inspired by two recent notices; the first is from a January 25 ENI Press Release crowing that “Eni is the first Italian company to receive that certification”. The second came from an article in the Financial…more
| Commercial Law & Contracts, International Law & Trade

Everything Compliance-Episode 7 [Video]

This episode is dedicated to the chaotic (at best) first three weeks of the Trump administration. Jonathan Armstrong leads a discussion of the Trump administrations devolution towards Privacy Shield and what it may portend…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Compliance into the Weeds-Episode 28 [Video]

In this episode, Matt Kelly and I take a deep dive into the new Microsoft security analysis tool, Secure Score which will rate a company’s IT and data security protocols. We use his blog post on the topic, “Microsoft…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law
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