All articles by Tom Fox – Page 21
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Stopping little lies before they become FCPA violations
What makes a fraudster? And how can a fraudster’s actions lead to larger complications for your corporation’s Foreign Corrupt Practices Act policies? Tom Fox sets out to answer these questions.
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Tales of crocodile tails under the FCPA
While the FCPA makes clear it prohibits providing anything of value to a foreign governmental official, who’s to say what has value? For U.S. officials, it could be jewelery, cash, or sports tickets. But for Chinese executives, it could be something more exotic, say ... crocodile meat? Tom Fox has ...
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Corruption becomes a political issue in Mexico
Tom Fox looks at Mexico’s struggle to turn itself around, beginning with a political discussion and the introduction of FCPA-like anti-corruption regulation. Is it a turning point or a false start?
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Is a cup of coffee a reportable FCPA violation?
What’s next on the list of FCPA violations, a cup of coffee bought for a custom official while you await inspection? Tom Fox ponders that question after reading about Lennox International’s $475 facilitation payment Justice Department disclosure.
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Just who are your friends?
Corruption in Hollywood? Tom Fox explores the controversy surrounding financing of the film, The Wolf of Wall Street, which the Justice Department claims was funded by the looted Malaysian sovereign wealth fund 1MDB.
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Tell us everything you know
Getting credit for cooperating with the Department of Justice is getting a whole lot tougher. Tom Fox explores.
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Galaxy Note 7 and an independent set of eyes
Tom Fox looks at the case of Samsung—which bucked the regular procedures used by other telecoms and self-tested its Note 7 batteries—to see how independent oversight would have made the difference in the outcome.
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The Nu Skin FCPA enforcement action reminds all of the cost of non-compliance
Tom Fox looks at the recent enforcement action against Nu Skin: a one-time bribe equals a one-transaction enforcement action.
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At PDVSA, the costs of corruption extend to bond swaps
Tom Fox explores anti-corruption lessons gleaned from Venezuelan national energy company Petróleos de Venezuela’s failed debt swap offer.
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Is Weatherford under another FCPA investigation?
A recent SEC announcement regarding a $140M penalty Weatherford paid to settle charges that it inflated earnings mentioned a continuing investigation. What’s curious, notes Tom Fox, is that those investigating are known for their work in FCPA enforcement.
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Was the GlaxoSmithKline FCPA resolution a missed opportunity?
Tom Fox questions whether U.S. regulators missed a chance to illustrate how they would give credit for anti-corruption prosecutions done by other governments in the case of GlaxoSmithKline’s China subsidiary’s recent FCPA resolution.
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The FCPA and the fight against terrorism
Tom Fox looks at the U.S. government’s linking of corruption and terrorism and its intention to use the FCPA as incentive to enact and enforce strong international and domestic anti-corruption and anti-bribery laws.
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Will Wells Fargo lead to more whistleblowing?
Tom Fox looks at expert opinion on whether the recent accounting scandal at Wells Fargo will be used to enhance whistleblower laws and regulations.
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Of soccer, cheating, and Sam Allardyce
The sacking of English football manager Sam Allardyce for explaining how to cheat at football to an undercover sting newspaper operation is an important reminder why the top of an organization sets the tone, says The Man From FCPA Tom Fox.
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Singapore’s increased AML scrutiny might affect everyone
As Singapore considers cracking down on money laundering, the impact of such a move may ripple far beyond that nation’s own banking system. Tom Fox has more.
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Reflections on the compliance profession from the SCCE Compliance and Ethics Institute
The Man From FCPA Tom Fox reflects on the changing role of the compliance practitioner and other lessons learned at the recent 15th annual SCCE Compliance and Ethics Institute in Chicago.
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Sir Andrew Witty successor named: GSK revisited
Tom Fox looks at Sir Andrew Witty’s career as chief executive of GlaxoSmithKline, as the CEO recently resigned and was replaced by Emma Walmsley.
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Whistleblower awards and new scrutiny of SEC enforcement
The SEC’s successful whistleblower bounty program is raising some very interesting questions about the future of whistleblowing in general. Tom Fox reports on the agency’s recent enforcement actions.
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Memo to Telia, Deutsche Bank: Do not negotiate with the DOJ in public
While Telia Co. and Deutsche Bank are looking to publicly war with the Justice Department over upcoming penalties, they should be learning by Avon Product’s example, says Tom Fox—the firm initially suggested a $12M fine and ended up paying a cool $135M.