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Foreign Corrupt Practices Act (FCPA) Compliance Corporate Culture

Thomas Fox - Compliance Evangelist

Tone at The Top Week: Part 2 – Ten Things A CEO Can Do

In corporate compliance, a guiding principle is the foundation for success or failure: Tone at the Top. This phrase encapsulates the role of senior executives—particularly the CEO—in setting the ethical standards, cultural...more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Lessons on Incentives and Discipline from Star Trek: Mirror Mirror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

Thomas Fox - Compliance Evangelist

Bridging The Speak-Up Gap: Insights from The 2024 Ethisphere Ethical Culture Report

In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 3- A Toxic Culture and the Fraud Triangle

We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 2 – Attributes of a Toxic Corporate Culture

We continue our exploration of aspects of corporate culture. Today, we turn to the dark side by reviewing some of the characteristics of a toxic corporate culture. An article in the MIT Sloan Management Review provided some...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 1- Redesigning Culture

In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...more

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Compliance Programs, Part 2

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco....more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Latham & Watkins LLP

DOJ Announces New Whistleblower Program

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DOJ unveils a new whistleblower incentive program to complement the Department’s continued efforts to encourage self-reporting of criminal violations. On Thursday, March 7, 2024, US Deputy Attorney General Lisa Monaco...more

Miles & Stockbridge P.C.

DOJ Provides a Contemporary Spin on ‘Wanted’ Posters: New Whistleblower Rewards Program Announced

U.S. Deputy Attorney General Lisa Monaco delivered keynote remarks March 7 at the American Bar Association’s 39th National Institute on White Collar Crime. Emphasizing the need for a culture of compliance, Monaco highlighted...more

Thomas Fox - Compliance Evangelist

Tailored and Effective Compliance Training

One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of compliance. While it seems...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Categories Key Compliance Speeches from 2023-DAG Monaco on a Culture of Compliance

In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity.  The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 3 – The Comeback

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Thomas Fox - Compliance Evangelist

Infortal Worldwide Geopolitical Risk Intelligence 2023 Outlook: Part 3-Corruption Intelligence

I recently had the opportunity to visit with, Chris Mason, VP Global Compliance & Investigations at Infortal Worldwide and Dr. Ian Oxnevad, Director, Geopolitical Risk at Infortal Worldwide for a sponsor podcast on Infortal...more

Thomas Fox - Compliance Evangelist

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4-A Training Program for 3rd Parties

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

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Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

Thomas Fox - Compliance Evangelist

Corporate Case Management in the Era of the DoJ’s Monaco Memo: Speak Up Culture

Welcome to a special five-part podcast series, entitled Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions (i-Sight). Over this series, Jakub Ficner, Director of Partnership...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from the World Series: Part 2 – Trey Mancini; Defense in a Best Practices Compliance Program

We continue our celebration of the Houston Astros winning the 2022 World Series by considering defense in baseball and prevention and detection in a best practices compliance program. According to Stephanie Apstein, writing...more

Society of Corporate Compliance and Ethics...

CEP Magazine - November 2022. Two sides of the coin: Proactive versus reactive compliance management

CEP Magazine - November 2022 - Before getting into compliance management, it is opportune to consider proactive and reactive management as a process. Proactive managers control their destinies by thinking ahead and...more

Thomas Fox - Compliance Evangelist

It’s The Great Pumpkin Charlie Brown – Lessons in Process Validation Through Continuous Monitoring

Halloween is almost upon us and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts...more

Thomas Fox - Compliance Evangelist

Great Structures Week IV –  Gothic Cathedral and Compliance Incentives

I continue my Great Structures Week with focus on great structural engineering and its innovations in the medieval world – that being the Gothic Cathedral. I am drawing these posts from The Great Course offering, entitled...more

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