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Foreign Corrupt Practices Act (FCPA) Corporate Culture Ethics

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

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 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

The Volkov Law Group

Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III)

The Volkov Law Group on

The Stericycle FCPA case is yet another example of a complete culture and compliance breakdown.  As I often repeat myself, there is no more important control than an ethical culture.  When a culture veers into the unethical...more

The Volkov Law Group

2022 Ethics and Compliance Predictions

The Volkov Law Group on

Ethics and compliance professionals believe in their mission – if they did not, they would not be in the field. E&C professionals believe in the power of positive thinking, ethical conduct, and in the overall ability of an...more

Thomas Fox - Compliance Evangelist

Crisis Week: Part 2 – Building a Compliance Culture to Withstand Crisis

Perhaps the most prescient comment I heard during the height of the pandemic came from Jed Gardner, Group Director of Transformation at Linedata, which was that we have moved from disaster recovery to business continuity to...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 9th - 12th, New Orleans, LA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

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Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

Thomas Fox - Compliance Evangelist

Countdown to 500 – Matt Kelly on the Evolution of Business Reporting on Compliance

We are on the final countdown to Number 500. Next week, on Monday, August 31, I will be celebrating my 500th Anniversary episode, where I will talk about some of the key changes I have seen in compliance over the past 10...more

Thomas Fox - Compliance Evangelist

The ROI of Effective Compliance and a Webinar to Boot

We are now at a place where there is sufficient data, academic research and actual use cases from corporations and businesses that demonstrate good ethics and compliance programs are not simply good for business but when...more

Thomas Fox - Compliance Evangelist

Evaluating Compliance Programs For Continuous Improvement

I recently had the opportunity to visit with Stephen Martin, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more

Thomas Fox - Compliance Evangelist

Arthurian Week: Part 1 – The Pentecostal Oath and Code of Conduct

What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...more

Thomas Fox - Compliance Evangelist

The Astros Players and Communicating Compliance

The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more

Thomas Fox - Compliance Evangelist

The Role of HR in Creating an Ethical Culture

The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...more

Society of Corporate Compliance and Ethics...

[Event] April Basic Compliance & Ethics Academy - April 27th - 30th, Chicago, IL

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 5: The Whistleblower and The Amnesty

I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more

Society of Corporate Compliance and Ethics...

[Event] March Basic Compliance & Ethics Academy - March 2nd - 5th, San Diego, CA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

The Volkov Law Group

Turning a Turbulent Social and Political Environment into Positive Ethical Culture Strategies

The Volkov Law Group on

Corporate cultures do not operate in a silo or free from external influences.  Yet again, another profound grasp of the obvious.  Employees, managers and senior leadership all bring their own experiences, perspectives,...more

Barnea Jaffa Lande & Co.

Compliance and Ethics in Corporations

The United States has been the global leader in the enforcement of anti-bribery and anti-corruption laws for several decades. The Foreign Corrupt Practices Act (FCPA) was enacted in the United States in 1977 in order to...more

Thomas Fox - Compliance Evangelist

HorrorFest 2019 Celebration – The Films of Val Lewton and Role of the Compliance Function

In the 2017 FCPA Corporate Enforcement Policy, the Department of Justice (DOJ) listed the following factors relating to a corporate compliance function, that it would consider as indicia of an effective compliance and ethics...more

Thomas Fox - Compliance Evangelist

Day of Reckoning for KPMG-Failures in Ethics

The day of reckoning was here for KMPG and I do not think that anyone could have imagined how bad it would be for the firm. Last week the Wall Street Journal (WSJ) reported last week that KPMG was preparing to pay up to $50...more

Thomas Fox - Compliance Evangelist

The Design of Business Ethics

How can you design an ethical organization? Is it different from one which does business in compliance with anti-corruption laws such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act (UKBA)? ...more

Thomas Fox - Compliance Evangelist

What Are Your Risks?

What are the largest risks to a corporation? How have those risks continued to morph and change? What are some of the top enforcement priorities of agencies and regulators? Finally, what is the compliance response to both...more

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