News & Analysis as of

Department of Justice (DOJ) COSO

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - June 28th, 8:25 am - 4:30 pm CT

Achieve your ESG goals in 2023 - Environment, Social, and Governance (ESG) is a top priority for organizations of all types and sizes, and it the compliance team is a key factor in the ESG equation. Much like regulatory...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

Thomas Fox - Compliance Evangelist

Doing Compliance in an Economic Downturn

The city of Houston has seen a multi-year economic downturn from the drop in the price of oil. Every company in the energy space has been required to dramatically cut its work force, including unfortunately, it compliance...more

Thomas Fox - Compliance Evangelist

Evolving Best Practices in FCPA Compliance Training

As Houston, TX, is the epicenter of Foreign Corrupt Practices Act (FCPA) enforcement, most energy companies in my hometown have mature compliance programs or at least more mature than in other industries, which have not gone...more

Thomas Fox - Compliance Evangelist

Highway 61 Revisited Week – Highway 61 and IRS Involvement in FCPA Enforcement

One of the most difficult stories of the Bible for me was always that of God and Abraham. But somehow this song explained it for me as it deals with some unusual problems that can be solved out on Highway 61, which is a...more

Thomas Fox - Compliance Evangelist

Is Strict Liability Coming to FCPA Enforcement?

I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether...more

Thomas Fox - Compliance Evangelist

Welcome to COSO and the World of Internal Controls – Part I

I have intentionally avoided a Top Five or Top Ten prediction list for Foreign Corrupt Practices Act (FCPA) enforcement going forward from 2014 into 2015. However there is one area of FCPA enforcement, which I think underwent...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom

In this episode Compliance Week editor Matt Kelly and I discuss the COSO 2013 Framework implementation and its changes from the prior Framework. We also discuss the recent Bruker Corp & Dallas Airmotive FCPA enforcement...more

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