Rethinking FCPA Due Diligence in a Hyper-Transparent Environment
Stakeholders and customers are increasingly calling for transparency from corporations in how and with whom they’re doing business. As a ...
Tag: Tone at the Top
DOJ’s Pilot Program: Carrot and Stick or Bluff and Bluster?
The Department of Justice launched an initiative to encourage self-reporting of FCPA violations, promising up to 50 percent reductions in ...
The Skinny on the DOJ’s FCPA Pilot Program
With international bribery and corruption investigations hitting new highs, the DOJ announced a pilot program urging companies to self-report violations ...
Checking in on “The Year of Third-Party Due Diligence”
Given that most companies rely on hundreds – if not thousands – of third parties, it’s understandable that due diligence ...
Lessons From the PTC Enforcement Action
Lessons From the PTC Enforcement Action: How To Avoid More Grief Around Gifts, Travel & Entertainment Under the FCPA Sometimes ...
The VimpelCom FCPA Enforcement Action
By Tom Fox In what can only be termed a stunning resolution, the Department of Justice and Securities and Exchange ...
Data Analysis and Compliance
This paper by Tom Fox, with Joe Oringel, discusses the use of data analysis in a best practices compliance program ...
Novartis Coughs Up $25M to SEC for FCPA Violations in China
Novartis recently settled with the SEC – to the tune of $25 million – for violations of the FCPA in ...
Will the FCPA Go Down Under (Again)?
The chief executive of the Australian Securities Exchange resigned early last week amid allegations of his involvement in a foreign ...
New Pemex Corruption Risks
Organizations doing business with Pemex have long faced FCPA risks, as the company is controlled by the Mexican government and ...
The FCPA: A Major Opportunity For SEC Whistleblowers, Part 2
Dan Hurson’s in-depth experience prosecuting and defending white-collar criminal cases, and particularly under the Dodd-Frank Act. This piece provides insight ...
