News & Analysis as of

Ethics Dept. of Justice

This Week in FCPA-Episode 77, the Home for the Holidays Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner,...more

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

by Thomas Fox on

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...more

Astros Garner First World Series Win – Execution of Compliance in the Middle

by Thomas Fox on

In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more

Compliance Man Goes Global-Episode 4-Training

by Thomas Fox on

Welcome to Episode 4 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on typical myths and mistakes regarding compliance trainings. In each podcast, we take...more

Farewell to The Hawk – Fair and Consistent Application of Discipline

by Thomas Fox on

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Day 20: What Does Innovation in Compliance Look Like?

by Thomas Fox on

As I end this section on innovation, I want to conclude by laying out a road map which allows a CCO or compliance practitioner to make more effective and better operationalize a corporate compliance program. With the DOJ’s...more

A New Owner and New CEO: Will Anything Change?

by Thomas Fox on

Tilman Fertitta has purchased the Houston Rockets from current owner Les Alexander for the stunning sum of $2.2 bn. The sales price breaks the National Basketball Association (NBA) record sale of $2 billion from when the...more

The Week in FCPA-Episode 67, the Post Harvey Edition

by Thomas Fox on

After a two week absence, Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories which happened while we were off, including: 1. Retired U.S. Army colonel, Joseph Baptiste...more

How Do We Define ‘Effective’ for an ‘Effective Ethics & Compliance Programme’?

by NAVEX Global on

In the past year, we have seen a salvo of standards and regulations across the globe offering guidance on how to develop effective ethics and compliance programmes. Along with providing guideposts for programme leaders, the...more

Voluntary Monitoring – Multiple Purpose Tool in Compliance

by Thomas Fox on

Alan Peckolick, died last week. According to his obituary in the New York Times, he “overcame a failed art school career to emerge as a leading designer of some the world’s most distinctive logos”. In an interview with the...more

The Pull & Push of Compliance Policies & Training

by NAVEX Global on

“…companies used to bring in binders full of their policies….I really don’t care what the policy says….I’m more interested in how the policies actually operate.” That’s a quote from Hui Chen from an interview with...more

Workplace Ethics & Culture: What the Uber Board Report Means for Compliance Officers

by Thomas Fox on

A compliance perspective on one of the most unique corporate documents you will ever see....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 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

by Thomas Fox on

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more

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

by Thomas Fox on

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

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

by Thomas Fox on

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Unfair and Unbalanced-Episode 18

by Thomas Fox on

In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the...more

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

by Thomas Fox on

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....more

Understanding Special Counsel Mueller’s Authorization

by Michael Volkov on

Deputy Attorney General Rosenstein’s appointment of Special Counsel Robert Mueller last week was a blockbuster development in the investigation of the administration....more

FCPA Compliance Report-Episode 327, Pat Harned on Highlights from the ECI 2017 Conference

by Thomas Fox on

In this episode, I visit with Pat Harned, Chief Executive Officer of the Ethics and Compliance Initiative on the recently concluded annual conference. She discusses the speech of Attorney General Jeff Sessions and the panel...more

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine

by Thomas Fox on

Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more

Day 8 of One Month to Better Compliance Through HR-Using Compensation to Operationalize Compliance

by Thomas Fox on

One of the areas that many companies have not paid as much attention to in their Foreign Corrupt Practices Act (FCPA) anti-corruption compliance programs is compensation. However the Department of Justice (DOJ) and Securities...more

AG Jeff Sessions Left Compliance Officers with More Questions than Answers … and an Invitation

by NAVEX Global on

Attorney General Jeff Sessions was a keynote speaker at the 2017 Ethics & Compliance Initiative’s Annual Conference last week. Whatever your politics are, it was important that we hear from him on his priorities for...more

Day 1 of One Month to Better Compliance Through HR-the Role of HR in Operationalizing Compliance

by Thomas Fox on

This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long advocated for a greater role of Human Resources (HR) in a compliance program. Indeed, one sign...more

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