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NAVEX

Risk & Compliance as a Strategic Imperative for the Board

NAVEX on

In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

Womble Bond Dickinson on

In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 4 – ABB Shines

We continue our exploration of the latest resolution of a Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is from the fact that ABB is now the...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 1 – Introduction

Late last week, the Department of Justice (DOJ) announced a highly anticipated resolution of Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is...more

Thomas Fox - Compliance Evangelist

A Toxic Culture and the Fraud Triangle: Part 1

The fraud triangle is well-known to most compliance practitioners. It is pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to violation of law....more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action

The long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was recently announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more

Thomas Fox - Compliance Evangelist

Follow the Money: The Polycom and Eletrobras FCPA Enforcement Actions

The Polycom and Eletrobras FCPA enforcement actions present several important lessons for Chief Compliance Officers. Tom Fox explores....more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 77, the Home for the Holidays Edition

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner, it...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 57, the Father’s Day Edition

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

Thomas Fox - Compliance Evangelist

2016 - A Year for the FCPA Record Books & What It Means for Compliance Practitioners

We have never seen and may well never see again a year of Foreign Corrupt Practices Act corporate enforcements as we did in 2016. ...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 54, the Rubber Match Edition

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA

I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

Data Analytics Week – Part IV: Third Parties and Duplicate Invoices

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Thomas Fox - Compliance Evangelist

Data Analysis Week – Part III: Data Analysis to Prevent Employee Fraud

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Thomas Fox - Compliance Evangelist

Bristol-Myers Squibb FCPA Enforcement Action

Yesterday, the Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action against Bristol-Myers Squibb Company (BMS) for the actions of the company’s joint venture (JV) in...more

Morrison & Foerster LLP

5 Takeaways From Former SAP Exec's FCPA Case

On Aug. 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International Inc.) pled guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act. In addition to pleading...more

Thomas Fox - Compliance Evangelist

Mifune Gets a Star on the Walk of Fame-the Petrobras Scandal Only Gets Worse

(...) I had always thought that the Hollywood Walk of Fame honors actors but it turns out that it honors a great many more performers. For instance, next year will also see names like LL Cool J, Cyndi Lauper, Shirley Caesar,...more

Thomas Fox - Compliance Evangelist

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for May 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part II – The Golden Gate Bridge and Employment Separation – Hotlines and Whistleblowers During Layoffs

I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 124, The Oscars and Compliance, Part I with Jay Rosen

In this episode I begin a five-part series on the Oscars and Compliance with recovering Hollywood screenwriter Jay Rosen. In this Part I, we review the process by which films are nominated for the Oscars and the campaigns...more

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