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Corruption Fraud Compliance

SCCE Compliance and Ethics Institute – Eugene Soltes and How Compliance Programs Works

by Thomas Fox on

The first full day of the SCCE 2017 Compliance and Ethics Institute (CEI) featured a talk by Eugene Soltes, an associate professor at Harvard Business School and author of “Why They Do It”. For this book Soltes spent over...more

For the Benefit of Mr. Kite – Fiction in the World of Quality Assurance

by Thomas Fox on

The basics were laid out by Peter Wells and Emiko Terazono in a Financial Times (FT) article entitled “Kobe Steel scandal hits Boeing, Toyota and Nissan”. The Japanese company admitted it had falsified “inspection data on an...more

It’s A Slam Dunk: Take Steps Now To Avoid Tough Lessons Learned By Several NCAA Basketball Programs

The recent indictment of at least 10 individuals associated with college basketball should alert every university, and many businesses, to the importance of operating strong ethics and compliance programs and conducting...more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Midnight Cruising with Steely Dan – Finding Patterns in Raked Leaves

by Thomas Fox on

Last Friday on September 1, I began a new installment of my year-long podcast series, where each month I focus on a different compliance topic. This month, I am focusing on innovation in compliance....more

White Collar Watch (July 2017 • Vol 1, Issue 2)

by Blank Rome LLP on

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

What Happened in Oslo Shouldn’t Stay in Oslo - Corporate Compliance Insights

Fresh on the heels of the Anti-Korrupsjons+Konferansen in Norway, Richard Bistrong offers a look inside the conference and details some of the key takeaways. Originally published in Corporate Compliance Insights....more

Preparing for an Investigation

by Thomas Fox on

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investigation by Qualified Personnel – How...more

First 100 Days of the Trump Administration and The FCPA – Same As It Ever Was

by Thomas Fox on

Over the weekend, we had the first 100 days of the Trump administration. To commemorate this constructed time for review of any new administration I gathered the Everything Compliance podcast panel of Mike Volkov, Jay Rosen,...more

Termination of a Third-Party – Planning Can Reduce the Pain

by Thomas Fox on

The European concern Airbus has been in the news recently for corruption issues. According to an article in the Financial Times (FT), entitled “Airbus sued by middlemen fired following fraud inquiry”, its annual report lists...more

Brazilian Corruption Scandals Continue

by Thomas Fox on

The stench of corruption continues to bedevil Brazil, even as the clean-up initiated with Operation Car Wash is ongoing. This time, allegations of bribery and corruption have reached one of Brazil’s most prestigious exports,...more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

by Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Insight from the DOJ Fraud Section

by Robins Kaplan LLP on

Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more

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

by Thomas Fox on

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

Recidivism Under the FCPA: Zimmer Biomet

by Thomas Fox on

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

Forecasting, Risk Management and Compliance

by Thomas Fox on

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

Compliance Isn’t Going Away (and neither should you) – Part I

by Thomas Fox on

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

When the Compliance Counsel Speaks, CCOs Should Listen

by Thomas Fox on

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

From Altamont to Airbus

by Thomas Fox on

What was one of the most tragic events in the history of rock and roll? High up on the list must rank the Altamont concert, held at Altamont Race Track on December 6, 1969. It was so bad that many people felt the 60s actually...more

Joe Howell on the PCAOB, Audits and Compliance – Part IV

by Thomas Fox on

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

Joe Howell on the PCAOB, Audits and Compliance – Part II

by Thomas Fox on

Today we have Part II of my exploration with Joe Howell about the PCAOB and how its work with public company auditors impacts anti-corruption compliance. I asked Howell about auditor rotation and what it means. Howell...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

by NAVEX Global on

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

Foreign Corrupt Practices Act 2015 Update

by BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

New Citywide Construction Fraud Task Force Promises Tough Enforcement

by Bracewell LLP on

On August 5th, the Manhattan District Attorney (the "DA’s Office") announced the formation of a multi-agency Citywide Construction Fraud Task Force that will be spearheaded by prosecutors from the office. Its mission is...more

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