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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.

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

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

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

The Stoic's Guide to Compliance

by Thomas Fox on

One thing about successful Chief Compliance Officers (CCOs) and other compliance practitioners is they can take in severe news, keep calm and carry on. In a keynote speech to the SCCE Compliance and Ethics Institute, Jenny...more

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

by Thomas Fox on

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more

The Spirit of Compliance

by Thomas Fox on

One of my weekend pleasures is reading Peggy Noonan’s column in the Wall Street Journal (WSJ). Each week is filled with wit and insight and some of the finest writing around. This past week, in an article entitled “Why...more

Corporate Investigations and White Collar Defense - May 2017

Government Officials Pledge Continued White Collar Enforcement - Why it matters: Recent pronouncements by Attorney General Jeff Sessions, Acting Principal Deputy Assistant Attorney General Trevor N. McFadden and recently...more

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

by Thomas Fox on

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

This Week in FCPA-Episode 54, the Rubber Match Edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Operationalizing Compliance: Part IV – Internal Audit

by Thomas Fox on

This week I am engaging in a week-long 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 am...more

Operationalizing Compliance: Part I – It All Starts with Pizza

by Thomas Fox on

With the release of their Evaluation of Corporate Compliance Programs (Evaluation) in February, the Department of Justice (DOJ) emphasized yet again the importance of actually doing compliance and not simply having a paper...more

The Astros, Regression to the Mean and Compliance

by Thomas Fox on

Being a Houston baseball fan has been largely pain, misery and suffering. While we have not gone 80+ years or even a century without winning a World Series it is not for lack of ineptitude. It is because the Houston Major...more

Four Essential Leadership Behaviors

by Thomas Fox on

The role of any leader should be engagement, engagement and then more engagement. By understanding the needs of your key stakeholders and incorporating that into your solution or initiative you will have your team on board...more

SEC Enforcement Activity Declines In an Era of Uncertainty

by Dorsey & Whitney LLP on

It is axiomatic that markets hate uncertainty. So apparently do market regulators. A report on SEC enforcement activity shows a significant decrease in the number of enforcement actions brought in the first half of fiscal...more

Attorney General Sessions reemphasizes DOJ commitment to FCPA enforcement, individual accountability: 4 takeaways for business

by DLA Piper on

As the Trump Administration wraps up its first 100 days, practitioners have a bit more clarity regarding how the new Administration will assess corporate compliance programs, cooperation and white collar cases. Over the past...more

Data Analysis In a Compliance Best Practices Program

by Thomas Fox on

An in-depth look at the use of data analysis in a best practices compliance program under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act or other anti-corruption compliance regime....more

The Risk Management Process in Compliance

by Thomas Fox on

An exploration of risk forecasting, risk assessment and risk-based monitoring for the compliance profession. ...more

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