All articles by Tom Fox – Page 9
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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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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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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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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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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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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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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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Using investigative findings as the basis of remediation
There is nothing like an internal whistleblower report about an FCPA violation to trigger the board of directors and senior management attention to the compliance function and the compliance program.
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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.”
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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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FIFA sends a letter
Under the FCPA there must be more than simple communication of instructions to not engage in bribery and corruption. Yet, FIFA only wagged its finger and said “do not engage.” Makes one wonder if the organization is actually ready to change.
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South Africa reminds the FCPA covers political parties
For any company doing business in South Africa, all your contacts with the African National Congress have FCPA implications; This means all the investigations you might be performing for contracts with the South African government, anything associated with the Gupta family or state-owned enterprises, should be assessed for ANC contacts ...
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Why board oversight matters, in investing and compliance
The case of Outcome Health is a clear lesson for the anti-corruption compliance practitioner: Levels of oversight not only provide a backup to make sure that no mistake should slip through, but also the rigor of financial oversight.
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Financial incentives in a compliance program
You must be able to evolve in your thinking and professionalism as a compliance practitioner to recognize the opportunities to change and then adapt your incentive program to make the doing of compliance part of your company’s everyday business process.
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Tone in the middle of an organization
What should the tone in the middle be? This role is critical because the majority of company employees work most directly with middle, rather than top management and, consequently, they will take their cues from how middle management will respond to a situation.
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VW: The comeback begins
VW is currently demonstrating it can use a corporate scandal to wipe the corporate slate clean by refocusing on the emerging technologies for a greater business share.
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The end of Japan Inc.?
What happens when a series of scandals so engulfs a country that its entire national brand is put in jeopardy? Japan may have the answer.