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Best Management Practices Foreign Corrupt Practices Act (FCPA)

NAVEX

The Importance of Benchmarking Your Compliance Program

NAVEX on

Sometimes questions about corporate compliance programs can be more complicated than they first seem. Such was the case when a compliance officer recently asked me, “Can you point to anything specific that says why compliance...more

Mitratech Holdings, Inc

Why Is Vendor Management Software So Crucial For Financial Institutions?

Vendor management is a complex task, yet a necessary undertaking for any organization dealing with third parties.  ...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report-Episode 382, Susan Divers on LRN’s 2018 Program Effectiveness Report

In this episode Susan Divers, Senior Advisor at LRN returns to talk about "LRN’s 2018 Program Effectiveness Report."...more

Thomas Fox - Compliance Evangelist

Retooling Your Compliance Program

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 as a way to retool the focus of your compliance...more

Thomas Fox - Compliance Evangelist

Leadership Lessons from Mutiny on the Bounty

In honor of February and its traditional run up to the Oscars, in my podcast on business leadership, 12 O’Clock High, a podcast on business leadership, I am exploring leadership lessons from Oscar-winning Best Pictures. In...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 154-Compliance Leadership-Persuasion, Influence, Tools & Tips, Skills and Tips

In this episode, I discuss some of the tools which a compliance practitioner or CCO can use to further compliance in an organization. ...more

K&L Gates LLP

How to Conduct Internal Investigations Outside the United States

K&L Gates LLP on

Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more

Thomas Fox - Compliance Evangelist

Get Your Tootsie-Frootsie Ice Cream; Hiring as Part of Your Compliance Program

One of my great loves is the Marx Brothers. I fell in love with their rapid-fire wiseacre remarks as a teenager and have been enthralled with them since then. I have seen all of their movies, most of their television...more

Thomas Fox - Compliance Evangelist

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Thomas Fox - Compliance Evangelist

Sherlock Holmes and Innovation in the Compliance Function, Part I – A Study In Scarlet

Today begins a week of double themed blog-posts. First I am back with an homage to Sherlock Holmes, for it was in the magazine Beeton’s Christmas Annual that the characters Sherlock Holmes and Watson were introduced to the...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I

In this episode 88 of the FCPA Compliance and Ethics Report, I visit with noted internal controls expert Henry Mixon on the types of internal controls needed for third parties in a FCPA compliance program. ...more

Thomas Fox - Compliance Evangelist

Language as a Long Term Compliance Strategy

I constantly rely on Jay Rosen and his team at Merrill Brink for translation and other language related services in the compliance portion of my work. (Yes I do practice law and compliance for a living; I blog for gratis.) ...more

Thomas Fox - Compliance Evangelist

Risk Assessments-the Cornerstone of Your Compliance Program, Part II

One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different approaches in his article “Practical Suggestions for Conducting Risk...more

The Volkov Law Group

FCPA Compliance Programs A Review of Best Practices

The Volkov Law Group on

In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. Whether your company is large, medium or small, it is important to stay abreast of industry best practices....more

The Volkov Law Group

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

The Volkov Law Group on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance programs. ...more

Thomas Fox - Compliance Evangelist

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Thomas Fox - Compliance Evangelist

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part II

This one is tough, especially in global organizations. In many countries, you simply cannot run a background check, as criminal records are not public. In others, you can run them, but the criminal offense must be related to...more

Thomas Fox - Compliance Evangelist

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

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