The final installment from Tom Fox in a series on the Alstom FCPA enforcement action, this post explores the accounting records violations the French parent company owned up to. As it happens, the charges are a bit puzzling, but it's made clear in the settlement not only that there were some serious misdeeds afoot, but that there were ...
The recent Alstom enforcement action has dwarfed many others, and for Tom Fox, it brings to mind last summer's soccer upset heard 'round the world - Germany trouncing Brazil in the World Cup. Today's piece delves into the deferred prosecution agreements, outlining the requirements they set for Alstom and what they mean for compliance practitioners in general.
The first in a series of posts from Tom Fox on the recent Alstom enforcement action -- among the very largest of all FCPA actions to date both in terms of the scope of the investigation and the amount of fines levied against the offending party. Lessons to be learned from Alstom? The importance of controls cannot ...
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 ...
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.
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 ...
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 ...
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.
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 ...
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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