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The Foreign Corrupt Practices Act Chief Compliance Officers

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.

Compliance Lessons From Burner Phones

by Thomas Fox on

Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more

Slippery Slopes: “Broken Windows” and Employee Misconduct

by Michael Volkov on

Criminologists have debated for years the efficacy of the law enforcement strategy of “broken windows.” In simple terms, the theory suggests that minor infractions or petty crimes should be vigorously prosecuted in order to...more

Your Company Brand and Ethical Behavior

by Thomas Fox on

Last week, I was interviewed by David Banks, the Senior Content Marketing Manager at NAVEX Global, for the firm’s blog. One of the questions he posed to me struck me and it was “When it comes to contributing to a greater...more

The Emperor Has No [Compliance Program]

by Michael Volkov on

At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more

Using Data to Improve Your Compliance Bench Strength

by Thomas Fox on

In the September edition of One Month to a More Effective Compliance Program, I am focusing on innovation in compliance. There are many ways to innovate through the use of data. One of the interesting ways is through hiring...more

Day 4 of One Month of Innovation in Compliance-Welcome to ComTech

by Thomas Fox on

What will be the role of Artificial Intelligence (AI) in compliance going forward? LawTech had disrupted the legal profession and how it is reshaping many areas of private practice. I found the article had multiple...more

Soft Skills in Remediation: Part V – Post Resolution

by Thomas Fox on

I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more

DOJ's FCPA Pilot Program is Alive and Well: Two Superior Results in Declinations for Linde Gas and CDM Smith

by Thomas Fox on

Companies have a clear road map to resolve substantive FCPA violations with no criminal penalty. ...more

Soft Skills in Remediation: Part IV – When Are You Done?

by Thomas Fox on

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

Soft Skills in Remediation: Part III – Communications with Stakeholders

by Thomas Fox on

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

Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring

by Thomas Fox on

Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more

A Chief Compliance Officer's Guide to Investigations

by Thomas Fox on

Tom Fox in conversation with Jonathan Marks, who has laid out a concrete way for CCOs and c-level executives to think through how to plan an investigation, staff it properly and meet the inevitable challenges. ...more

New FASB Revenue Recognition Standard-Revenue from Contracts with Customer

by Thomas Fox on

We are now less than six months away from a new Revenue Recognition standard which may significantly impact the compliance profession, compliance programs and compliance practitioners going forward....more

Good-Bye to the Wichita Lineman – Know Your Values and Stay True to Them

by Thomas Fox on

Glen Campbell died yesterday. He was truly an American original. He grew up dirt poor, as a sharecropper’s son, near Delight (pronounced DEE-light), Arkansas and went onto to achieve worldwide fame. While many will remember...more

Workplace Ethics & Culture: What the Uber Board Report Means for Compliance Officers

by Thomas Fox on

A compliance perspective on one of the most unique corporate documents you will ever see....more

FCPA Risks and Acquisition Integration Challenges

by Michael Volkov on

Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Astros Lead MLB – What is Your Risk Management Process?

by Thomas Fox on

Today’s lesson from the world of sports informs our discussion of compliance and the risk management process; consisting of forecasting, risk assessment and risk management. By starting with forecasting, a compliance function...more

Trump and Compliance: The First 100 Days [eBook]

by Thomas Fox on

Since November 9, 2016 the Apocalypse has not descended (at least as of the writing of this foreword). Since that time many of the leading compliance commentators have considered what the first 100 days of the Trump...more

FCPA Digest - July 2017 - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act

by Shearman & Sterling LLP on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

Effective FCPA Compliance Programs: Building a Compliance Defense

by Dorsey & Whitney LLP on

The classic 1957 American mystery film “Three Faces of Eve,” about a woman with multiple personalities, may well describe the approach taken by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

The PCAOB, Audits, and Compliance - Considerations for the Chief Compliance Officer

by Thomas Fox on

I recently had the chance to visit with Joe Howell, the Executive Vice President of Workiva LLC, to discuss, among other things, the function of the Public Companies Accounting Oversight Board (PCAOB) and what role it might...more

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

Day 11 of One Month to Better Investigations and Reporting-Investigative Challenges

by Thomas Fox on

Today, I want to consider some of the challenges you may well face during an investigation. I am once again joined by Jonathan Marks, a partner at Marcum LLP and well-known investigations expert. Beyond the basics, a company...more

Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation

by Thomas Fox on

Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...more

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