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Senior Managers White Collar Crimes

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

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

Bank of America’s Corporate Culture Crisis: Part 5- A Case Study for Compliance

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 3-The Role of Internal Controls

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Seyfarth Shaw LLP

UK Criminal Liability Alert: Safeguarding Companies Operating in the UK From the Actions of Their Employees

Seyfarth Shaw LLP on

New criminal laws in the UK will make companies more vulnerable to criminal prosecution for the acts of their employees and agents than ever before. The Economic Crime and Corporate Transparency Act 2023 (“ECCTA”) introduces...more

K&L Gates LLP

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

K&L Gates LLP on

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 3 – Penalty Calculation and No Monitor

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

The Volkov Law Group

Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on

At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China.  Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more

Mitratech Holdings, Inc

5 Essential Elements of Corporate Compliance

Most experts agree that whichever regulatory jurisdiction an organisation is subject to, there are five common fundamentals involved in providing effective corporate compliance....more

The Volkov Law Group

Wells Fargo Settles With Justice Department for $3 Billion

The Volkov Law Group on

This year, 2020, has been an enforcement year opening with billion-dollar settlements: first, Airbus settled FCPA charges for $4 billion, and now Wells Fargo for $3 billion.  What a start to an enforcement year!...more

The Volkov Law Group

The Future of Compliance – The New Proactive CCO (Part III of III)

The Volkov Law Group on

The path of the compliance profession has been remarkable.  Recently, I have seen a number of tweets and postings from compliance thought leaders touting the accomplishments of compliance and the transformation of the...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 1 – Management Commitment

Yesterday, while honoring Ginger Baker who passed away this weekend, I began a multipart series on the Framework for OFAC Compliance Commitments (Framework). Mike Volkov has called this Framework a “game-changer” and has...more

Thomas Fox - Compliance Evangelist

Jim Langer, the Undefeated Dolphins and in the Trenches of Compliance

While leadership at and from the top has long been considered by both the DOJ and compliance professionals as a key element to move compliance forward, the 2019 Guidance focuses our attention around compliance leadership from...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s New Corporate Compliance Evaluation Guidance

Key Considerations and Updates for Life Sciences Companies - On April 30, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) issued updated guidance for white-collar prosecutors on evaluating the...more

Thomas Fox - Compliance Evangelist

Boards and Corporate Culture: Part II

Today, is the second in a two-part series based on an interview with Rakhi Kumar, Senior Managing Director, Head of ESG Investments and Asset Stewardship, at State Street Global Advisors (SSGA) and SSGA’s recent...more

Thomas Fox - Compliance Evangelist

Why Innovation is Required in Compliance

Why is innovation so critical in every compliance program? Is it simply because the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) say it is so; or are there other reasons?...more

Thomas Fox - Compliance Evangelist

Kinross-Lessons Learned on Internal Controls and Internal Audit

Yesterday the Securities and Exchange Commission (SEC) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action involving Kinross Gold Corporation (Kinross). ...more

Thomas Fox - Compliance Evangelist

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"The New UK Corporate Offence of 'Failure to Prevent the Facilitation of Tax Evasion': Implications for Fund Managers and...

The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more

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