All articles by Tom Fox – Page 8
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Wells Fargo continues to trip on itself
Wells Fargo cannot seem to get out of its own way to begin to move forward. Now, the bank is facing a whistleblower lawsuit and investigation by the Consumer Financial Protection Bureau for closing fraud victims’ accounts without investigating potential criminal activity, a violation of law.
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What has Latvia wrought?
U.S. banking regulators have long understood the connection between bribery, corruption, money laundering. and security. It will be interesting to see if the ECB and European countries are willing to become as aggressive as their U.S. counter-parts in fighting the global scourge of money laundering.
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Loss of trust and internal investigations
If your stakeholders do not trust you, they will not confide in you in a meaningful manner. Many commentators talk about business ethics, but it may all start with business trust.
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Board’s prudent discharge of compliance obligations
A look at how board members might want to enhance their prudent discharge to shareholders in regard to the FCPA, as the SEC and Justice Department could be giving it their full attention.
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OIG guidance for boards on compliance
It turns out that 2015 guidance from the OIG provides an excellent roadmap in today’s world for how companies can structure a compliance committee for their board and for the board’s obligations.
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Social media basics for the CCO
Building a robust Twitter feed is a must-have in every compliance toolbox. As such, compliance professionals need to brush up on social media.
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Former PdVSA officials face corruption-based civil lawsuit
A look at the first civil action filed in Houston for the massive PdVSA bribery and corruption that engulfed the company and those who tried to do business with it over the past few years.
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Facilitation payments under the FCPA
In addition to its restrictions, a key to FCPA compliance is accurately recording facilitation payments going forward. As with all things FCPA-related, the “document, document, document” mantra holds.
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Extortion policies under the FCPA
An extortion payment, while not a violation of the FCPA, should have its own set of policies and procedures that employees adhere to per the chief compliance officer.
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Charitable entities and compliance
The stories of Plan International USA and of Oxfam make clear the need for robust compliance programs in a non-profit charity.
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Bad days ahead for Shell and ENI?
The bribery allegations against Shell and Italian energy company ENI makes one wonder: If monies paid to a foreign government itself are now subject to scrutiny, could it open up an entirely different exposure to liability for international organizations?
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Why is the U.S. government investigating GlaxoSmithKline now?
GlaxoSmithKline recently said U.S. enforcement agencies asked for information about third-party advisers the company hired in China during a corruption investigation in the country. The Man From FCPA asks, why now?
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The intersection of cyber-security with the compliance professional
New York’s Department of Financial Services (DFS) has issued the first state level regulations on cyber-security for financial institutions, but non-financial services industries should take heed of them as well.
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Continuous monitoring to continuous improvement
To continuously improve a compliance program, the compliance team should apply a consistent set of protocols, checks, and controls tailored to the company’s risks. Tom Fox offers some guidance on how to do just that.
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Does your board have a compliance expert?
The Federal Reserve Bank this month assessed a penalty against Wells Fargo for the bank’s widespread customer abuse from its fraudulent accounts scandal, other regulatory violations, and lack of response by the bank’s doard of directors to these problems and other risk management issues.
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The effects of corruption at home
Petrobras (of Operation Car Wash fame) will soon consider offers to sell a refinery located in Pasadena, bringing the effects of the FCPA home to the United States.
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Deficiencies in ISO 37001
As the drumbeat of those supporting ISO 37001 continues, The Man From FCPA takes a look at the standard’s downside.
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How suppliers facilitate fraud and corruption
Compliance officers should always remember there is a bribe receiver in a corruption case. That is why it is important to know not only your third party, but also with whom you are doing business.
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What is a conflict of interest?
A look at the case of Dr. Brenda Fitzgerald, the now former head of the Center for Disease Control, who invested in tobacco stocks after she became director.
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Compliance tone at the bottom
Even with a great tone-at-the-top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the “tone at the bottom.”