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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 ...

tacoma narrows

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.

giants fans

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 ...

discipline

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?

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Lessons from GSK in China – Internal Controls, Auditing and Monitoring

Take a closer look at GSK's failures in China and they seem so obvious. There are some key lessons for professionals in the compliance space to learn from their significant oversights--namely lacking controls, deficiencies in auditing and a breakdown in monitoring. We should be mindful of the warnings implicit in the GSK enforcement actions.

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To the NFL – Show More Than Ethics, Show Some Humanity

The NFL has been all over the news lately, and it's not for any of its teams' upsets or losses. Not on the field, anyway. Two scandals involving domestic violence -- and the league's treatment of the perpetrators -- have led to public outrage, with many viewing the punishments, initially little more than a slap on ...

football

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... ...