All articles by Tom Fox – Page 5
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Podcast
Tom Fox podcast: Setting the right tone at the top
In the first of a weekly series on the 10 hallmarks of an effective compliance program, Compliance Week columnist Tom Fox discusses the importance of senior leadership in setting the tone for the company.
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Podcast
Tom Fox podcast: Importance of code of conduct, policies and procedures, and internal controls
In the second of a series on the 10 hallmarks of an effective compliance program, Compliance Week columnist Tom Fox discusses the three components of written standards of a best-practices compliance program: the code of conduct, policies and procedures, and internal controls.
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Blog
GDPR is live ... now what?
With GDPR now in effect, we should soon start to get some answers regarding its enforcement and how its private right to action will play out in the legal arena.
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Blog
Compliance in the middle is critical
One of the most important parts in the corporate hierarchy is the often-overlooked middle of an organization. Inside is an in-depth look at what tone in the middle should be.
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Blog
Improving your compliance strategy
Communicating your compliance strategy can be a critical problem when operationalizing compliance, but there are some best practices companies can follow.
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Blog
Avoiding and overcoming GDPR challenges
When GDPR becomes effective on May 25, compliance practitioners will have to be ready for those areas that will be most impacted by the regulatory change.
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Blog
Novartis GC resignation points to compliance themes
The resignation of Novartis GeneraI Counsel Felix Ehrat shows companies the importance of distinguishing between the legal and compliance functions and why you should always get a business justification before working with third parties.
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Blog
Wells Fargo charm offensive
New Wells Fargo ads in prominent business newspapers are an effort to let the world know the bank is cleaning up its act—but, without follow-through, it may not be enough.
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Blog
ZTE and the Arthur Andersen myth
Remember the myth of Arthur Andersen—that if you go to trial in a corruption case and lose, the company will be irreparably harmed? That myth may have arisen once again in the form of a U.S. president criticizing U.S. regulators for penalizing Chinese company ZTE.
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Article
D&B shows the right way to handle an FCPA probe
The D&B enforcement action should be studied by every compliance practitioner for tips on preventing an FCPA issue and what to do if you find one.
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Blog
Malaysia gets new PM; further probes of prior regime coming
The election of a new Prime Minster in Malaysia has heralded a potential investigation into the allegations of massive corruption carried out by the prior administration surrounding the country’s sovereign wealth fund, 1MDB.
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Blog
Uber promises to ‘move forward,’ but still doesn’t have CCO
Uber launched a new ad campaign in which it vows to “move forward” and “always do the right thing,” but the company still does not have a chief compliance officer (CCO) to make sure it delivers on that message.
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Blog
Checklist for CCO direct reports
Inside are some factors to consider when assessing chief compliance officer direct reports and what the Justice Department expects from the direct reporting process.
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Blog
The benefits of tailored compliance training
A thoughtful look at focusing compliance training on an employee-by-employee basis could mean the difference in keeping corporate compliance on the right track.
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Blog
Not-so-neutral Switzerland probes 1MDB
Switzerland has joined the investigation into Malaysia’s state development fund 1MDB in what could be the first steps toward heightened AML stratagems for the often-detached country.
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Blog
What signal will Germany send on VW?
What effect will the U.S. indictment of former Volkswagen CEO Martin Winterkorn have on German prosecutors? Will Germany have the desire to indict and try the former head of the world’s largest auto manufacturer and pride of Germany?
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Blog
Operational excellence for better compliance
By focusing on the business process nature of compliance, you can create a more effective compliance regime.
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Blog
Autonomy verdict and FCPA defenses
A recent case involving Autonomy and Hewlett-Packard shows that it is not the bribe receiver’s conduct but the bribe payor’s conduct that matters.
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Blog
Learning lessons from FCPA enforcement actions
Two FCPA enforcement actions against Panasonic and Hewlett-Packard Mexico are good reading for the compliance practitioner and offer lessons in stamping out fraud.
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Blog
The ‘20 percent’ lesson learned from Panasonic Avionics
Compliance practitioners take note: Cooperating with FCPA investigators was literally worth millions to Panasonic Aviation.