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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Now displaying: Page 1
Aug 6, 2018

What is the purpose of rehabilitation in a best practices compliance program? In this episode, I use the recent trade by the Houston Astros for closer Roberto Osuna last week as an introduction into several areas around compliance, discipline, punishment and zero tolerance. Osuna had been charged with violating the Major League Baseball (MLB) policy on domestic abuse. This weekend Osuna came off a 75-game suspension. It involved an incident for assault, for which Osuna pleaded not guilty to in a criminal case in Ontario. As part of this discussion, I consider several questions.

  • What is Zero Tolerance? Does it apply at all times or is it applied only situationally?
  • What is Due Diligence and how does an organization know if it has performed a sufficient level of DD?
  • What effect does or should any of this have on employee morale?
  • What is the purpose of rehabilitation?
  • What is the purpose of discipline in an organization?
  • What is deterrence?

For more reading see my blog post Due Diligence, Zero Tolerance and Compliance.

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