Pro Football and the FCPA Professor

Ah, September: bringer of fall, sweater weather, and football. Compliance practitioners and lovers of football alike can appreciate the parallels between the sport and the nuts and bolts of FCPA compliance. The success of both teams relies heavily, for instance, on a strong understanding of the game plan. Tom Fox outlines a few other shared characteristics... ...


Trying Something Different – The Desktop Risk Assessment

Those with less adventurous palates can relate: some of us aren't big on trying new things. But when it comes to risk assessments, sometimes taking a new approach can do you good. Tom Fox shares a novel strategy, the desktop risk assessment, which is a more focused, yet limited take on the more common exhaustive assessment.

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Termination of a Third Party, or Breaking Up Should Not Be Hard To Do

Good, bad or ugly, all things must come to an end. Third-party relationships are no exception. Fortunately, companies can prepare for these ends, whether the relationship has simply run its course or there's been a breach of contract. Planning for the end is essential if you want to ensure a smooth transition. Here are five ...


John Bell Hood and the Measurement of Conduct Risk

History might be told a bit differently if risk conduct analyses were common practice. These days, there's as much need as ever to address conduct risk, setting policies, incentive structures and enforcement practices in our organizations that reward good conduct and penalize acting contrary to the companies' values and regulatory standards.


No Sex Please, We’re British: More from GSK in China

The GSK China scandal came to light through a sex tape, and the anonymous whistleblower who leaked the tape also presented allegations of bribery. GSK's own investigation into the matter has failed to net anything of substance, but the Chinese government has turned up a great deal of evidence pointing to massive systemic bribery.


In Due Diligence and World Cup Bids: Follow the Money

In the past month, we've heard plenty of allegations of corruption associated with the Brazil World Cup, but there's as much or more controversy surrounding the forthcoming events in Qatar. Tom Fox suggests that when there's a question of corruption, just follow the money. And in this case, it's flying in all sorts of questionable directions.

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Coolness in Being the Bad Guy? Eli Wallach and GSK

GlaxoSmithKline has gotten plenty of negative attention lately for allegations of widespread corruption in its China operations, accusations that may cause irreparable harm to the pharma giant. Regulatory bodies far and wide are jockeying for position to charge GSK, sending the message that corruption will not be tolerated. Compliance practitioners, take note!

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Common Sense in the Definition of “Instrumentality” Under the FCPA

An opinion released Friday by the Court of Appeals offers some much needed clarity on just what organizations are considered “instrumentalities” under the Foreign Corrupt Practices Act. Here, Tom Fox explores this decision, as well as early amendments to the FCPA supporting the Court’s findings and methods for establishing instrumentaility. The findings seem to be based entirely ...