All articles by Tom Fox – Page 10
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The end of the compliance defense debate
Over the years, there has been a siren’s call for the addition of a compliance defense to the FCPA. It’s time to send the so-called “compliance defense” packing.
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South Africa sets up corruption commission
The Man From FCPA explores South African President Jacob Zuma’s intent to set up a nationwide corruption commission to look into allegations of rampant corruption through looting of government agencies and state-owned entities.
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Compliance and the immigration debate
The raids by ICE last week on 7-Eleven stores nationwide portend a good reason to document, document, document, and The Man From FCPA suggests you go back and double check your documentation at both your corporate headquarters and at each location, so if the government comes raiding, you will be ...
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Wells Fargo still suffering financially from scandals
Wells Fargo is one of the poster children over what can happen when compliance is not taken seriously or perhaps not at all in an organization.
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What is your investigation protocol?
If you follow this basic protocol from The Man From FCPA, you should be able to work through most investigations, in a clear, concise and cost-effective manner.
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Non-monetary and indirect cost of a FCPA investigation
The Man From FCPA recently spoke with Dan Chapman, CEO of Presyse Compliance, about his experience with the non-monetary costs and indirect costs of a major FCPA investigations.
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Oh thank heaven?
Tom Fox explores the recent raids by agents from the U.S. Immigration and Customs Enforcement (ICE) of 7-Eleven stores across the country, looking for undocumented workers from an FCPA perspective.
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More fallout from Och-Ziff corruption case
In an interesting turn of events, the Och-Ziff corruption case recently reared its head once again, following news that Michael Cohen—who once oversaw the company’s investments in Europe, the Middle East and Asia—is facing criminal charges of fraud and obstruction of justice, according to recently unsealed court documents.
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How character relates to compliance
Merely having in place a paper compliance program does not account for the human condition, which unfortunately is not always pure of heart, writes The Man From FCPA, while considering a recent book, “The Character Gap,” by Christian Miller.
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The Fair Process Doctrine in compliance
Human resources has a key role to play in operationalizing the compliance program, specifically by ensuring that discipline is handed out fairly across the company and to those employees who integrate ethical and compliant behavior into their individual work practices, writes The Man From FCPA.
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The role of risk management in compliance
As compliance evolves and corporate compliance programs become more sophisticated, compliance is seen not as simply a legal prophylactic, but as a business process, writes The Man From FCPA.
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Ruling against PwC may portend greater auditor scrutiny
A court ruling in a lawsuit brought by the Federal Deposit Insurance Corporation against PwC for its failure to detect a multibillion-dollar fraud may well portend greater skepticism and scrutiny by auditors when looking at FCPA issues.
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The stunning Petrobras securities lawsuit settlement
In a stunning capitulation, Petrobras settled with U.S. investors for nearly $3bn in a class-action lawsuit as follow-on litigation to the long-standing corruption allegations against the company.
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CCO authority and independence
The more the Justice Department talks about CCO independence, coupled with resources being made available and authority concomitant with the CCO position, the more corporations will see it is in their best interest to provide the resources, authority, and gravitas to compliance positions within their organizations.
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The role of global payroll in compliance
When it comes to following the money and staying in accordance with Department of Justice regulations, global payroll is the most well-suited corporate discipline to provide first-level oversight and controls.
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The desktop risk assessment
If you perform an annual Desktop Risk Assessment with a full worldwide risk assessment every two years, you should be in a good position to keep abreast of compliance issues that may change and need more or greater risk management.
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Where is your backup?
A power outage at Atlanta’s Hartsfield Airport is a reminder to us all that having backup systems in place is essential to good business.
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The imperial CEO
Former GE CEO Jeff Immelt managed in a way that he could have a backup private jet follow him around, but never had time to speak with the person managing the fleet...or to let the Board know about his infamous "ghost plane."
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Compliance and employment separation
Before beginning any layoffs, it is essential that the compliance practitioner work with the legal department and HR function to make certain employment separation documents are in compliance with SEC rules.
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What newspapers do you read?
In this day and age, it would be wise for chief compliance officers to keep on top of the news, especially when it regards corruption, says The Man From FCPA.