Thomas-Fox

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Seamus Heaney and Compliance With a Seat at the Table

When assessing compliance challenges ahead of an expansion into a new market, the CCO or compliance practitioner has quite the job on his or her hands. Tom Fox offers up four basic questions to consider when walking through analysis, third-party due diligence and developing a plan to ensure ongoing compliance both with the FCPA and any in-country regulatory ...

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Bobby Keys, the Rolling Stones and Establishing Trust

While due diligence is essential when doing business with or through third parties, ultimately trust is critical in maintaining successful business relationships. No matter how thorough the questionnaire or how in-depth the business justification, even well-vetted partners can do you wrong if the relationship consists of a series of box-ticking encounters. Don't overestimate the power of transparency.

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Doing Business in India – Corruption Risks and Responses

A recently released whitepaper from Foley & Lardner and India-based MZM Legal offers much-needed guidance on maintaining compliance with the FCPA while doing business in India. Tom Fox has done the heavy lifting already, however, and provides CCI readers today with a glimpse into the piece and highlighting some of the greatest corruption risks and how to manage ...

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Supplier Risk Management – Interconnected Processes

The processes driving large-scale change are necessarily interconnected. The same can be said for the processes involved in risk management within the supplier chain. Tom Fox outlines six overarching steps for effectively identifying and mitigating supplier risks -- one leading feeding directly into the next -- in order to maintain anti-corruption and anti-bribery compliance among third ...

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Don’t Collapse in the Wind – Knowledge is Power

A tongue-in-cheek bit of discourse from Tom Fox on the wealth of information provided us on the FCPA at literally zero cost, and how FCPA practitioners leverage this information for their own financial gain. Is profiting from free information wrong? Decide for yourself. But this expert won’t be packing up his office anytime soon.

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Giants Join Pantheon of Greats Through the Confluence of Culture and Strategy

The San Francisco Giants grasped their third World Series win in five years last week. In the course of the championship, the team demonstrated what many compliance practitioners know to be true: that compliance and strategy make good bedfellows. When a company or sports team, as the case may be, is armed with both, they're primed for ...

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Right to Retire Or Termination: Remediation of Leadership To Foster Compliance

Tom Fox raises an interesting question: when fault is found with leaders at the heart of a scandal or a major violation, they may face termination - but should they be allowed to retire instead, benefits intact? Here he explores three recent examples of corrupt leadership and the companies' subsequent responses. There are some key lessons ...

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Tommy Lewis, Dicky Maegle and the DOJ Call for Individual Prosecutions

Acts of criminal misconduct are - almost without fail - carried out either by an individual or a group of individuals, so it stands to reason that the DOJ would focus its efforts on individual prosecutions rather than to bring charges against the company itself. The company's participation in any resulting investigation is expected, but it should tread ...

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Ringo, Sir Paul and an Effective Compliance Program

There's more than one way to skin a cat - whether we're talking about putting on an incredible rock show or running an effective compliance program. Keep in mind, though, that however your compliance program is fleshed out, if and when an investigation begins, the DOJ will look not only at its components, but also how it's been ...

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Discipline and Rigor in Your Internal Controls

Those seeking to abuse the system will find a way to do it, so it's imperative that companies implement strong internal controls and then continually strive to strengthen them further. Make no mistake, detecting and preventing FCPA violations takes discipline, but initiatives and activities undertaken with discipline generally pay off, don't they?