News & Analysis as of

Bribery FCPA Guidance Corporate Governance

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 1 – Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more

Thomas Fox - Compliance Evangelist

Tribute to Diana Rigg and Assessing International Internal Controls

You could begin with the Transparency International-Corruption Perception Index (TI-CPI) to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in...more

Thomas Fox - Compliance Evangelist

Taming Complexity in Compliance

One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more

Thomas Fox - Compliance Evangelist

The Problems with Facilitation Payments

The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more

Thomas Fox - Compliance Evangelist

Wuthering Heights Week Part I: Integrity Agenda Framework

This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more

Thomas Fox - Compliance Evangelist

Defects in the ISO 37001 Certification

The drumbeat of those supporting ISO 37001 continues. However, I still find it to be misplaced as anything close to the international standard for anti-bribery/anti-corruption programs....more

Thomas Fox - Compliance Evangelist

Operationalizing Compliance: Part V – Controller’s Office

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

Thomas Fox - Compliance Evangelist

Doing Business In Italy - Step Up Your FCPA Compliance Now

Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more

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