All articles by Tom Fox – Page 22
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Why pre-acquisition due diligence and post-acquisition remediation are so critical
Tom Fox looks at a recent SEC settlemenf for and FCPA enforcement action against Jun Ping Zhang, which makes clear the need for robust pre-acquisition due diligence.
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The (non) myth of the 5,300 rogue employees
The Man From FCPA, Tom Fox, asks why it is always the employee’s fault when a corporation engages in fraudulent activity leading to regulatory fallout. Perhaps the CEO of Wells Fargo, responsible for the firing of 5,300 “rogue” employees for fraudulent activity, has the answer.
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SFO brings charges in Tesco accounting scandal
Tom Fox examines the Serious Fraud Office’s recent indictments against three individuals from the October 2014 Tesco scandal in which the British grocery chain overstated earnings by fraudulently accounting certain revenues received back from suppliers.
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Internal controls: trust but verify
Tom Fox looks at the recent scandal at Wells Fargo leading to the Consumer Finance Protection Board’s $185 fine and the firing of more than 5,000 employees after basically telling them: “It’s OK to break the law, as long as we make money.”
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Perception, reality, and global anti-corruption enforcement
Tom Fox looks at scandals involving Swedish business empire Industrivärden and Apple that point to an increasing need for good compliance programs in an age of corruption and social media.
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Compliance lessons keep coming from HP/Autonomy deal
HP’s legendarily bungled acquisition of U.K. software company Autonomy continues to provide valuable compliance lessons as well as one heck of a corporate governance horror story. Tom Fox reports.
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When good-intentioned sales incentives go bad
When do sales incentives move from the realm of legal to the realm of the nefarious? When do company communications become so code-word laden as to demonstrate corrupt intent? Tom Fox explores this latest trend that occurred at Fiat-Chrysler.
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Internationalization of football and anti-corruption enforcement
Tom Fox explores the recent bid by a Chinese state-controlled investment fund to purchase the Liverpool Football Club and how it will be impacted by the U.K. Bribery Act.
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Do the FCPA rules make sense?
How many rules are too many? How complicated are the rules to follow? These are questions Tom Fox explores in the context of the Foreign Corrupt Practices Act. Fortunately, the answer, he says, is quite simple—do not pay bribes.
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Will VW impact international settlements for bribery and corruption?
The Man From FCPA Tom Fox explores the fallout from VW’s emissions-testing scandal and how the company will make restitution going forward to its customers, dealers, and other stakeholders.
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Tone at the top really does matter
The Man From FCPA Tom Fox looks at the case of disgraced pharmaceutical company Valeant and what new Chief Financial Officer Paul Herendeen has planned for the company’s future.
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Target and Walmart show that supply chain risk is everywhere
The bigger the company, the bigger the supply chain risk. Just ask Target and Walmart, which recently had to confront this issue head-on over fake Egyptian cotton bedsheets. More from Tom Fox.
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In the FCPA World, your relationships matter
Do you know the character of those you are in business with from an anti-corruption perspective? Tom Fox looks at the Och-Ziff corruption scandal and what happens if you bring corrupt third parties into a relationship with your company.
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Potential VW criminal resolution—an early test for Yates Memo?
A look at potential VW criminal resolutions brings up several questions, says Tom Fox, around type of resolution; individual liability; and more. Will this test the DoJ’s Yates Memo?
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An employee suicide and corporate culture
The Man From FCPA Tom Fox examines the recent suicide of an executive with Abbot Laboratories in India and what happens when the numbers are more important than employees’ well-being.
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SFO Airbus investigation indicates new normal in financing and compliance
The Serious Fraud Office investigation into Airbus emphasizes the importance of compliance program best practices for borrowers in obtaining funding and loan guarantees, especially in light of the latest trend: government oversight. Tom Fox reports.
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The FCPA as an economic tool
The FCPA is rarely considered as an economoic tool. But as a means of fighting corruption, however, it also helps to improve market efficiency.
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DoJ sends clear signal in the LATAM/LAN FCPA enforcement action
A recent Foreign Corrupt Practices Act case found LATAM Airlines Group shouldering a heavy burden, paying out approximately $22.2 million in penalties. The significant costs, notes Tom Fox, seems to imply the Justice Department’s FCPA Pilot Program is working.
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AML due diligence for non-financial institutions: the next big thing in compliance?
What does the 1MDB scandal portend for non-financial companies and anti-money laundering compliance? Plenty, especially if they haven't reviewed their AML policies and procedures in the last 12 months. Tom Fox reports.
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FCPA compliance and the social contract
Tom Fox looks at how Foreign Corrupt Practices Act compliance promotes multiple corporate stakeholders.