All articles by Tom Fox – Page 3
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Blog
Joint venture risks under the FCPA
Joint ventures present a unique set of FCPA risks for the compliance practitioner, which is why companies need to incorporate risk management techniques in all phases of JV relations, pre-formation, the JV agreement, and in operations after the JV has begun operation.
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The role of the controller in business ventures
A close collaboration between the compliance function and the controller role portends a more robust picture of enterprise risk, one which encompasses legal, compliance, ethics, internal controls, financial, business, and governance.
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All eyes on the CBS board of directors
The role of the board of directors in a best practices compliance program takes on even more importance when senior management engages in recalcitrant conduct. It remains to be seen if the CBS board will step up in a time of crisis.
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Risk management 101: getting third-party approval of terms and conditions
While it may seem daunting to convince third parties to agree to the company’s terms and conditions, it’s a key part of compliance and one each party will appreciate in the end.
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What are your compliance resources?
Evolved Justice Department policies encourage corporations to see it is directly in their best interest to provide the resources, authority, and gravitas to the compliance position within their organizations.
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If geopolitical risks change, scrub your operations
The recent political upheavals in South Africa and Malaysia should serve as a reminder for companies to review their operations in politically evolving countries in which they might have conducted government business.
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Compliance lessons from the best team in baseball
Believe it or not, there's a compliance lesson to be learned by the methods of the Houston Astros in their rise from the worst team in baseball to World Series champions.
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Bank of England probe latest blow to KPMG’s reputation
Accounting firm KPMG has taken some serious reputational hits over the past several months ... and they just keep on coming.
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What is a business relationship?
The Man From FCPA ponders the FCPA considerations of electric-car company Tesla putting the squeeze on its suppliers by asking them to refund monies Tesla had paid to them, as far back as 2016.
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A fine mess in Brazil (and Houston)
A legal battle between Vantage Drilling and Petrobras, Brazil’s state-owned oil company, has put a new twist on contract challenges and FCPA violations
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The importance of auditing third parties
Auditing third parties is critical to any compliance program and an important tool in operationalizing your compliance program.
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Evaluation of third parties
Compliance practitioners at GE Oil & Gas discuss the process by which GE reviews the risks around each of its third parties.
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The ‘how’ question in due diligence
A clear lesson to be learned from the Theranos scandal is when conducting merger due diligence, make sure to determine how a new partner conducts itself and its business.
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Will a Goldman partner flip?
The former head of Goldman Sachs southeast Asia is reportedly in discussions with the Justice Department and will likely plead guilty to federal charges regarding his involvement with the 1MDB corruption scandal. What will his involvement mean for the company, which continues to deny culpability?
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Why HR compliance is critical to creating trust
The recent departure of Uber’s head of human resources suggests the company’s new speak-up cultural might not be all it’s cracked up to be.
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Law firm files alleged evidence of bribery against former client
U.K.-based mining giant Eurasian Natural Resources Corp. is suing its former counsel and U.K. regulator the Serious Fraud Office for their complacency in leaking information about an investigation into the company for alleged bribery and corruption.
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Hiring and the FCPA
The Credit Suisse FCPA enforcement action reminds us all again that it is not the hiring of family members or close friends of a foreign government official or employee of a state-owned enterprise that is illegal under the FCPA, only those hires made with corrupt intent.
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What is the cost of a subpoena?
Glencore has seen a drop in its share price, which could be related to the Justice Department having issued a subpoena for possible FCPA violations in the Democratic Republic of Congo, Nigeria, and Venezuela.
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Irony, FCPA enforcement actions, and M&A
Boeing’s planned acquisition of Brazilian company Embraer’s commercial jet business and LyondellBassell’s possible acquisition of Brazilian entity Braskem highlights an ironic twist to the FCPA: An enforcement action could be so financially draining that your company is forced to sell all or parts of itself, but results from that same ...
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Incorporating compliance into long-term corporate strategy
How can a board of directors work to incorporate the compliance function into a long-term business strategy of the organization? Tom Fox has a few ideas.