Thomas-Fox

compliance

Bristol Palin, Abstinence and the Compliance Defense

Newsflash: compliance programs are only effective when they're being put into practice. Having a paper compliance program is no kind of defense... just like claiming to be abstinent while acting otherwise didn't keep Bristol Palin from her latest pregnancy. And like Ms. Palin, some will find there are consequences of SAYING you're adhering to the compliance program ...

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Never Tick Off a Redbird

Baseball's St. Louis Cardinals are being investigated by the DOJ and the FBI for allegedly hacking into the Houston Astros' database. You read that right. One of the National League's best performing teams was after the secrets of one of the worst teams in the League. In a world where successful entities attempt to steal data ...

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FIFA, the DOJ and the Global Fight Against Corruption

The first step to recovery is admitting you have a problem. Let's grab onto that metaphor. Despite corruption that's been endemic for years, FIFA has not only not yet taken that first step, the organization is still balancing precariously on wobbly legs. With the DOJ having recently charged more than a dozen FIFA officials, however, the ...

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The FIFA Indictments and Travel Act Prosecutions under the FCPA

Last week, 14 officials and individuals associated with FIFA were indicted on corruption, racketeering, and conspiracy charges. And while the defendants haven't exactly violated the FCPA, U.S. authorities are bringing charges under the Travel Act, which prohibits the use of the mail or any facility in interstate commerce to engage in illegal activity.

interview panel

Levi Strauss and Auditing of Third Parties

This year's Compliance Week conference was rife with excellent speeches from compliance experts. Tom Fox shares with us the highlights of one presentation from Baker Hughes' Marianne Ibrahim and Jennifer Ellison, whose address on planning for audits was truly illuminating. A must-read piece for any practitioners establishing or tweaking their audit protocols.

game plan

A CCO Job Function: Managing Talent

CCOs have a big job, no question. In addition to developing and strengthening the compliance program and remaining attentive to ethical concerns throughout the organization, the CCO has the responsibility of managing his bench of compliance practitioners. Given the egos often prevalent among top talent, this is no small feat...

choices

Ruth Rendell and Developing Better Compliance Solutions

The late, great mystery writer Ruth Rendell was known for challenging human bias. As a result, her writing felt fresh while her contemporaries' novels were often formulaic and predictable. In the world of compliance, overcoming human bias when seeking solutions is even more important. Tom Fox explores how compliance practitioners can perfect their decision making.

fcpa tom fox

Deep Dive: SEC Enforcement of the FCPA

FCPA practitioners often focus only on DOJ enforcement issues. This article provides a deep dive into some of the key differences between DOJ enforcement of the FCPA with that of the SEC.

Mr. Spock

Farewell to Mr. Spock and Risk Assessment Under COSO

Mr. Spock and his pursuit of logic inform today’s blog post. Every compliance practitioner is aware of the need for a risk assessment in any best practices compliance program; whether that program is based on the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act or some other compliance law or regime.