News & Analysis as of

Board of Directors FCPA Guidance Compliance

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Executives Acting in Bad Faith and the Role of the Board

A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more

Thomas Fox - Compliance Evangelist

Day 25 | Compliance function in an organization

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it came to the corporate compliance function, 2012 FCPA Guidance, under...more

Thomas Fox - Compliance Evangelist

Day 24 | CCO authority and independence

This Hallmark was significantly expanded in both the 2019 Guidance and the FCPA Corporate Enforcement Policy. And in so doing, the DOJ has increased the prestige, authority and role of both the CCO and corporate compliance...more

Thomas Fox - Compliance Evangelist

Memo: Wells Fargo, Put a Compliance Professional on your Board

After almost two years, you might think that Wells Fargo, its senior management and Board of Directors would have gotten the message from its regulators to take its compliance obligations seriously, remediate and put ethics...more

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