All articles by Tom Fox – Page 24
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At one bank, lax compliance and internal controls are a 'cancer'
The Man from FCPA has seen a lot of strong statements from top management, but when a chief executive likens non-compliance to cancer, you know it is serious. But last week, Bill Winters, the chief executive of the UK bank Standard Chartered, did just that when he announced that he ...
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VW’s Dieselgate has finally reached the automaker’s C-Suite
The VW emissions-testing scandal has reached the embattled automaker’s C-Suite. It was only a matter of time. Tom Fox reports.
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Responsibility under the FCPA: persons vs. systems approach
How your company considers Foreign Corrupt Practices Act violations will inform its response. Inside, FCPA blogger Tom Fox examines the differences between a persons versus a systems approach when it comes to tackling those violations.
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Lax controls—a cancer at one bank
Bill Winters, CEO of the U.K. bank Standard Chartered may have set a new precedent for taking a hard stance on ethics and compliance recently, when he penned an angry memo to 1,500 top managers announcing steps he has taken to “stamp out the cancer of complacency and lax controls” ...
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On the myth of the ‘rogue employee’
Companies often use the myth of the “rogue employee” to try and absolve themselves from liability. But organizational wrongdoing is rarely the work of just one person, says FCPA blogger Tom Fox. More from Fox inside.
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Of shell companies, law firms, and the FCPA
An interesting development in the continued fallout from the Panama Papers may portend a new trend in Foreign Corrupt Practices Act enforcement. Tom Fox takes a look at NML Capital’s lawsuit against Mossack Fonseca for obstruction of justice.
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Want evidence about the FCPA Pilot Program?
Do you want to see evidence of the effectiveness of the Justice Department FCPA Pilot Program? Read on ...
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At FIFA, things are only getting worse
The FIFA corruption scandal continues to rock the world of international soccer with new allegations of wrongdoings by former president Sepp Blatter (above) and his cronies. FCPA blogger Tom Fox explores the conflicts of interest that arise when those in charge set, negotiate, and approve their own salaries.
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The Panama Papers: of shell companies and tax evaders
Long before the now infamous Panama Papers scandal made the headlines, Ryan Hubbs, a senior manager of fraud investigation and dispute services at EY, penned an article about shell companies that still resonates. Tom Fox discusses how this and other media can help companies avoid the same tragic fate.
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Should data thieves be compensated?
Under what circumstances should you reward a data thief who exposes criminal activity? Tom Fox looks at the case of Hervé Falciani, who was employed at the bank HSBC and stole the list of persons who banked there, including those who did so to engage in tax evasion.
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Tone at the top and (former) CEO consulting
What does retaining a disgraced CEO as a consultant tell you about tone at the top?
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Where will Brazil’s new president take Operation Car Wash?
Will Brazil’s interim president do away with the country’s fight against bribery and corruption? Early results are not promising, according to FCPA blogger Tom Fox, who offers a further look at recent troubles in the scandal-plagued country.
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Join me at Compliance Week 2017
Plan to attend Compliance Week 2017 to learn about the continued growth and operalization of compliance. Why should you consider attending an event one year out? It is because of the strength and character of Compliance Week 2016 that you should block this time off and plan to attend next ...
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Key theme from Compliance Week 2016
The continued evolution of the Chief Compliance Offiicer and compliance function was a key theme from Compliance Week 2016.
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CCO independence as key indicia of best practices compliance program
At the annual Compliance Week conference, U.S. Justice Department and Securities and Exchange Commission representatives spoke about what constitutes an effective compliance program under the Foreign Corrupt Practices Act and the increased importance of an independent chief compliance officer. Our Man From FCPA Tom Fox explores further.
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CCOs facing greater personal scrutiny from regulators
The Man from FCPA, Tom Fox, examines the recent FINRA disciplinary action against Raymond James CCO Linda Busby, in light of what appears to be broadening personal liability for chief compliance officers when it comes to FCPA enforcement.
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BlogOf power and responsibility
With great power comes great responsibility. The Norwegian Oil Fund already knows that, but it appears the company will give the entire world a responsiblity lesson as it takes more interest in the corporate governance policies of those firms in which it invests. The Man From FCPA Tom Fox has ...
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Is FIFA headed in the right direction?
Do FIFA's latest governance moves an indicator of a genuine effort to reform this embattled organization? Or is it just shuffling the deck chairs? The Man From FCPA Tom Fox reports.
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The Yates Memo and the new normal for individual enforcement
In a speech before the New York bar, Justice Department Deputy Assistant Sally Yates detailed some of the effects the Justice Department has already seen from the Yates Memo, released last September, including a larger focus on individual actor culpability and a drive by DoJ lawyers to identify the individuals ...
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A blizzard of corruption has 2016 off to a roaring FCPA start
There has been enough foreign corruption turmoil in the first few months of 2016 that one almost doesn’t want to see what the rest of the year has in store. It’s the kind of year where, already, the Petrobras and Dieselgate scandals seem like a century ago. Tom Fox reports.