All articles by Tom Fox – Page 4
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Payroll controls and compliance
How can payroll help when operationalizing a compliance program? Tom Fox explores payroll’s role and the four key areas that should be considered when reviewing compliance goals.
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The continuing problem of shell companies
Businesses must conduct more robust background checks and must work to improve their internal controls around all third parties to make sure one does not slip through the corporate cracks and cause great damage.
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Check your Hermès handbags and bank accounts
The scope of the corruption that befell 1MDB funds continues to widen, with an investigation uncovering a staggering amount of loot from the home of former Prime Minister Najib Razak. For companies doing business in or with Malaysia, now is the time to make sure all operations are free from ...
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Shell companies and the who of corruption
A key part of any fraud scheme are the attempts to keep it hidden, and many companies set up shell companies to do just that. A look at why shell companies can shield bad actors from the public record.
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Whistleblowers and building trust
It is now more important than ever for companies to take seriously internal whistleblower reports, get the reports into the hands of the corporate functions that can triage and investigate such information, and keep the whistleblower in the loop more fully as to the status of the investigation.
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Machine learning and anti-corruption compliance
Behavioral analytics, coupled with machine learning will enhance anti-corruption compliance programs and the company will run more efficiently, as it will allow an organization to more closely track its overall spend going forward.
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The importance of compliance contract terms
Making sure third-party contracts contain appropriate compliance terms and conditions can help save companies time and money down the road.
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Asking questions about your third-party process
When regulators come knocking, it’s important to have the right protocols in place. Knowing what questions to ask can be a big help to companies when implementing a third-party due diligence process.
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GM’s Shawn Rogers speaks candidly on training transformation
Compliance Week columnist Tom Fox recently sat down with Shawn Rogers, lead counsel, compliance training and communications at General Motors, to discuss the innovative steps GM has taken toward improving compliance training.
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Mergers and corporate culture
Big mergers are in the news, with the union of telecom giant AT&T and vast multimedia firm Time Warner and Comcast’s $65 billion bid for 21st Century Fox being just two examples. With the recent Justice Department emphasis on corporate culture, it will be interesting to see what this season ...
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No piling on requires global disclosure and cooperation
To receive the benefits of no piling on, companies must fully disclose their conduct and cooperate with regulators across the globe.
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Condos, corruption, and compliance
While President Trump promised condos in North Korea as a part of his negotiations with North Korean Supreme Leader Kim Jung Un, it doesn’t mean companies will have an easy time doing business in the country, which ranked as “highly corrupt,” on the 2017 Transparency International Corruption Perceptions Index.
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Phase 2 in third-party risk management: the questionnaire
An essential piece of third-party risk management is “the questionnaire,” which companies should garner on behalf of all their third-party relationships at the start of the union in order to move forward with all the anwers.
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What is due diligence?
Due diligence is key to getting your third-party risk management program off the ground.
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It could get messy for U.S. companies doing business in EU
Don’t be surprised if the EU uses new data privacy laws to combat any secondary sanctions it might face by the Trump administration for continuing to do business in Iran.
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The ZTE Department of Commerce Monitor: uncharted waters
As part of the resolution to free itself from a U.S. sanction, ZTE has agreed to the unique position of having a court-appointed monitor and one from the Department of Commerce, leading to concerns of a clash of ideas and authority.
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Business justification for the use of third parties
Why is business justification for third parties so important? With the Department of Justice, Securities and Exchange Commission, and Internal Revenue Service all seeking such justification, companies should definitely make it part of the compliance process.
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Best practices: Hiring a business sponsor for third-party relationships
A significant piece of the compliance regime is overseeing third-party business relationships, and the best way to keep them on track is to employ the business sponsor.
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Executives behaving badly—at what cost?
FCPA violations from SocGen and Legg Mason may point to a new trend of holding the C-Suite accountable, but will voluntary resignations be seen as enough of a penalty?
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What changed? FRC brings action in Autonomy scandal
The Financial Reporting Council has brought long-awaited charges against Autonomy executives for their role in the massive accounting fraud uncovered when Hewlett-Packard attempted to purchase the software firm in 2011.