Tom Fox is prolific writer on the Foreign Corrupt Practices Act. He publishes the excellent FCPA Compliance and Ethics Blog. One of the downsides to a blog is that it’s a running commentary and not a narrative guide. Blogs are great for sharing ideas among practitioners. But a blog does not come together as a … Read more »
Tag: Tom Fox
Compliance, the Tour de France, and Doping
One of the biggest challenges with any compliance program is proving effectiveness. It’s really hard to prove that you prevented a bad thing from happening. You may be able to detect bad things when they occur. But most policies and procedures cannot prove they capture 100% of the bad things. Cycling is a case in … Read more »
Compliance Bricks and Mortar – Mayan Apocalypse Edition
If you’re reading this, then the Mayan Apocalypse didn’t happen. (At least not yet.) That means back to work and a look at some of the compliance stories that caught my attention recently. Dispatches From the Front Lines of the Ethics & Culture Wars by Matt Kelly in Compliance Week Does your organization know what … Read more »
FCPA Opinion Procedure Release 10-02
A continuing quirk of the Foreign Corrupt Practices Act is the ability to ask the Department of Justice whether a particular set of facts would be a violation of the Act. Given all of the recent FCPA activity I expected there to be an uptick in Opinion Procedure Releases under the FCPA. So far that … Read more »