News & Analysis as of

FCPA Guidance

Soft Skills in Remediation: Part II – Project Timing

by Thomas Fox on

Today, I continue a five-part series on what a Chief Compliance Officer (CCO) needs to consider when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I am...more

Soft Skills in Remediation: Part I – The Gatekeepers

by Thomas Fox on

Many Chief Compliance Officers (CCOs) came to the position from the legal department, internal audit or another professional discipline. These professions are technically focused and their training provides little to no soft...more

Time for Compliance to Take a Stand

by Thomas Fox on

Chuck Duross has called the compliance profession “The Alamo” of corporate America, in that sometimes you must take a stand, draw a line in the sand and make the ultimate commitment to your values. Based upon the events in...more

The Mattis Memo On Ethics – Not Just For The Military

by Thomas Fox on

Earlier this week, Matt Kelly broke the story of Secretary of Defense James Mattis Memo on Ethics to all Department of Defense (DoD) employees, in a blog post entitled “Secretary Mattis’ Insights on Ethics”. On Wednesday,...more

Evolution of Your Compliance Program

by Thomas Fox on

One of the most consistent themes from the Department of Justice (DOJ) regarding Foreign Corrupt Practices Act (FCPA) compliance programs has been continuous evolution. As far back as 2009, I heard Lanny Breuer say that your...more

New Revenue Recognition Standard – Part VI: What Does Mean?

by Thomas Fox on

Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more

Using Your Employees to Innovate and Transmit the Message of Compliance

by Thomas Fox on

Yesterday I wrote about the use of internal employee crowdsourcing as an innovation tool for a Chief Compliance Officer (CCO) to enhance a best practices compliance program. Multiple readers noted the topic with approval and...more

Oh, Hadn’t You Heard? You’re Violating French Law Right Now! France Gets Serieuse about Anti-Corruption

Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more

The Government Uses Multiple Tools to Fight Corruption

by Thomas Fox on

There are multiple ways to deal with an issue which can provide known and unforeseen benefits. Today we celebrate one of those as it was on this day in 1944, that President Franklin Roosevelt signed the GI Bill into...more

Linde in the Republic of Georgia: A Declination and Lessons Learned

by Thomas Fox on

Yesterday the FCPA Professor reported the Department of Justice (DOJ) had issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the...more

The Investigation Team

by Thomas Fox on

Beginning with the Department of Justice’s (DOJ’s) Yates Memo, its Foreign Corrupt Practices Act (FCPA) Pilot Program and then the release of the Evaluation of Corporate Compliance Programs (Evaluation), I believe the DOJ has...more

The Uber Board Report – Part II: Internal Controls

by Thomas Fox on

I continue my blog post series on the Holder Report (Report) to the Board of Directors of Uber Technology, Inc. (Uber) where the Board asked Holder’s law firm, Covington & Burling LLP (Covington), to evaluate three issues:...more

Investigation Challenges

by Thomas Fox on

Today I conclude my three-part series on internal investigations with Jonathan Marks, a partner at Marcum LLP and a well-known internal investigation expert, by considering some of the challenges you may well face during an...more

Trial and Error in Compliance

by Thomas Fox on

One of the highest values in the corporate world is consistency. While being stubborn can be an asset in the corporate world, it can be risky but when it takes being consistent too far. ...more

2016 - A Year for the FCPA Record Books & What It Means for Compliance Practitioners

by Thomas Fox on

We have never seen and may well never see again a year of Foreign Corrupt Practices Act corporate enforcements as we did in 2016. ...more

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

From Bottom Bunk to Top Mind

I recently had the honor of being named to Compliance Week’s list of Top Minds for 2017, earning the title of “The Great Communicator” from Bill Coffin, Donna Rice, and the CW team....more

The Renovated Globe Theater and Operationalized Compliance

by Thomas Fox on

There is much that a Chief Compliance Officer (CCO) or compliance practitioner can learn from Shakespeare. I have often used his plays as introductions to blog posts or as examples to inform a compliance program. Today, I...more

From Dr. No to an Agile Compliance Program

by Thomas Fox on

How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more

AI and Compliance Going Forward: Welcome to ComTech

by Thomas Fox on

What will be the role of Artificial Intelligence (AI) in compliance going forward? In Wednesday’s Compliance into the Weeds podcast, Matt Kelly and I continue our discussion, that we began several years ago, of how technology...more

Doing Compliance in an Economic Downturn

by Thomas Fox on

The city of Houston has seen a multi-year economic downturn from the drop in the price of oil. Every company in the energy space has been required to dramatically cut its work force, including unfortunately, it compliance...more

FCPA Predictions for 2017 (Part III of III)

by Michael Volkov on

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs...more

Battle of the Somme Week – Part II: Lessons for the CCO from Analogic

by Thomas Fox on

Today, I want to focus on the planning phase of the Battle of the Somme, which led to the disastrous casualties sustained by the British. Although rarely mentioned, I think the accidental drowning death of Lord Kitchener,...more

New FCPA Guidance: DOJ Swings and Misses

On April 5, 2016, the Fraud Section of the Criminal Division, Department of Justice ("DOJ") released a policy document entitled, The Fraud Sections' Foreign Corrupt Practices Act Enforcement Plan and Guidance ("Guidance"), in...more

Alert: DOJ Launches New FCPA Voluntary Disclosure Pilot Program

Why it matters: After several months of promising greater transparency relating to charging decisions for corporations that voluntarily disclose potential FCPA issues, on April 5, 2016, the Department of Justice announced the...more

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