Thomas-Fox

hands raised

Asking Questions To Build Your Compliance Program

In the April issue of Inc. magazine, Paul Graham, Jim Collins and other business leaders looked at some of questions that business thought leaders should be asking of themselves and of their teams, many of which are directly applicable to compliance and ethics.

ukraine-flag

The Battle of Shiloh, Corruption in Ukraine and Things to Come

Monday marked the 126th anniversary of the ending of the the two-day battle of Shiloh. On the second day, the Union troops under General Grant largely recovered the ground that the Confederate troops had taken on the first day. Grant was severely criticized for allegedly being taken by surprise by the Confederate attack, but he managed to survive the ...

shady-guy

Something is Rotten in Denmark or Is It the Banking Industry?

“Something is rotten in the state of Denmark” is one of the signature lines from Shakespeare’s play Hamlet. I thought about that when I read recent articles, “Questions Are Asked of Rot in Banking Culture” and “Lawmakers Tell Justice Dept. to Seek Swiss Banker Extraditions.”

harriet-tubman

Harriet Tubman and Navigating to Become an Ethical Company

March 10th was the 101st anniversary of the death of Harriet Tubman. She was one of the greatest conductors on the Underground Railroad, which took slaves out of the old south and up to freedom in the north and into Canada. I read about her as a child and her story always moved me.

Niccolo Machiavelli

Machiavelli for Chief Compliance Officers

Last year was the 500th anniversary of the publication of one of the most significant books on political theory ever written, The Prince, by Niccolò Machiavelli. Just how evil do many people view the treatise as? Consider that this book alone is responsible for bringing the word “Machiavellian” ...

investigation protocol

What is Your Board’s Investigation Protocol?

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises. However, many Boards do not have the same rigor when it comes to an investigation, which should be conducted or led by the Board itself.

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The FCPA and Fight Against Terrorism

I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion in DOJ and SEC enforcement of the Foreign Corrupt Practices Act (FCPA).