News & Analysis as of

FCPA Guidance White Collar Crimes Board of Directors

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

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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