News & Analysis as of

FCPA Guidance Corporate Culture

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

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

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 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

The Volkov Law Group

Compliance Messaging: Need a Reason? ‘Tis the Season!

The Volkov Law Group on

As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....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

Rosie Ruiz and Ethically Challenged Employees

Once you demonstrate you are ethically challenged or maintain a moral flexibility that allows you to lie, cheat and steal; it is highly likely you will continue to do so....more

Thomas Fox - Compliance Evangelist

Dedication of the Empire State Building and Benefits of an Effective Compliance Program

Today at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference, Assistant Attorney General Brian Benczkowski delivered the afternoon Keynote Address. He gave some significant comments around the corporate...more

Thomas Fox - Compliance Evangelist

Shakespeare’s Problem Plays: Part 3 – Measure for Measure and Creating a Game Plan

Today, I conclude my short series on Shakespeare’s problem plays by considering Measure for Measure. In the age of #MeToo this play has taken on a renewed and frankly disturbing existence. ...more

Thomas Fox - Compliance Evangelist

Investigative Due Diligence - Innovation and Continuity

This week, on the FCPA Compliance Report, I am running a five-part podcast series on the current state of  investigative due diligence. ...more

Thomas Fox - Compliance Evangelist

The Process of Speaking Truth to Power

What is the best way for a Chief Compliance Officer (CCO) to speak truth to power? How do you speak up to stop something that might cause a legal violation such as under the Foreign Corrupt Practices Act (FCPA)...more

Thomas Fox - Compliance Evangelist

Monitoring and Compliance in the International Arena

This week I am running a special five-part sponsored podcast series with Vincent DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. ...more

Thomas Fox - Compliance Evangelist

Building an Ethical Organization

What allows major ethics and compliance scandals to continue to hit multinational organizations? When it involves bribery and corruption, the likelihood of a lengthy, extensive and expensive Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

How M&A Oversight Benefits from Independent Assessment

This week, I am running a five-past podcast series on the assessment of ethics and compliance in the mergers and acquisition (M&A) context. The podcast series was sponsored by Affiliated Monitors, Inc., (AMI)....more

Thomas Fox - Compliance Evangelist

Pre-Acquisition and Post-Closing Steps in M&A

This week I am running a five-part podcast series on assessing ethics and compliance in the mergers and acquisition (M&A) context on the FCPA Compliance Report. ...more

Thomas Fox - Compliance Evangelist

Wuthering Heights Week Part I: Integrity Agenda Framework

This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more

Thomas Fox - Compliance Evangelist

Farewell to V.S. Naipaul and Creating Priorities in Your Compliance Program

V.S. Naipaul died last week. He was a Trinidadian born grandson of Indian indentured servants sent to the island to work in the sugar plantations. From those humble beginnings, Naipaul rose to the heights of the literary...more

Thomas Fox - Compliance Evangelist

Leadership in Culture Change

This week I have been exploring how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more

Thomas Fox - Compliance Evangelist

Tribute to Keith Jackson and Breakthrough Strategies in Compliance

Keith Jackson died last week. He was universally recognized as the Voice of College Football and announced college football games for over 40 years. According to his obituary in the New York Times (NYT), Robert A. Iger, the...more

The Volkov Law Group

Three Simple Steps to Improve Your Corporate Culture

The Volkov Law Group on

What exactly does “corporate culture” mean?  Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean?...more

Thomas Fox - Compliance Evangelist

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

Thomas Fox - Compliance Evangelist

New FCPA Enforcement Policy Ends the Compliance Defense Debate

As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more

Thomas Fox - Compliance Evangelist

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

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

Thomas Fox - Compliance Evangelist

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

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

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