Thomas-Fox

rock show

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?

china

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.

football 2

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... ...

reading

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.

goodbye key

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 ...

cannon

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.

british

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.

construction

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.