Thomas Fox reviews the steps taken by Alliance One and Universal Corporation during the pendency of their respective FCPA investigations to reduce their fines for FCPA violations.
Thomas Fox entertains a few questions: What are the obligations of a Board member regarding the FCPA? Are the obligations of the Audit Committee under the FCPA at odds with a director’s “prudent discharge of duties to shareholders”? Do the words prudent discharge even appear anywhere in the FCPA?
Thomas Fox describes a new. readily accessible tool for FCPA trainers to use as an authoritative source for educating people who to deal with being solicited to pay a bribe.
If top management is not fully committed to such an ethical and compliance culture, such lack of commitment will be clearly understood by middle managers of a company. This is particularly true of the FCPA.
This past week the Department of Justice (DOJ) published its second FCPA Opinion Procedure Release of 2010, 10-02. Thomas Fox explains what it means for charitable donations under the FCPA.
This article concludes our series on what Thomas Fox believes to be the Top 3 FCPA cases in the first half of 2010. He reviews HP and its reported investigation for the alleged payments of bribes to secure a contract to sell computer hardware into Russia.
The recent enforcement actions against Veraz Networks provides some additional guidance for what types of gifts and entertainment can be provided without one running afoul of the FCPA.
As we enter the second half of 2010 it is time to review what we believe to be three of the more significant Foreign Corrupt Practices Act (FCPA) matters which came to significant public attention in the first half of this year. Today we begin with the Gun Sting case.
Thomas Fox discusses the ongoing debate in the compliance arena as to whom a Chief Compliance Officer (CCO) should report. There are a variety of setups, but is one approach more right or wrong than another?
Thomas Fox asks what will be the cost to your company for FCPA (non) compliance and are you willing to risk it? Or, are you willing to do something to prevent it?
