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Best Practices Corporate Misconduct Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Michelle Peirce from Hinckley Allen, where she co-chairs the White Collar and Government...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 3, Extensive Remediation

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

NAVEX

DOJ: Risk Is Not Static – So Your Compliance Program Can't Be

NAVEX on

On Thursday, July 30, Brian Rabbitt, Acting Assistant Attorney General for the Criminal Division of the U.S. Department of Justice (DOJ), participated in a Q&A session with the Ethics and Compliance Initiative (ECI). During...more

Thomas Fox - Compliance Evangelist

Day 29 of 31 Days to a More Effective Compliance Program

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root...more

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Thomas Fox - Compliance Evangelist

The Damaging Myth of the Rogue Employee

As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives...more

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