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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FCPA Compliance Report




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Now displaying: August, 2016
Aug 12, 2016

In this episode, Jay Rosen and I discuss the following:

1. SEC In-House ALJ Program Upheld. Compliance Building and Second Circuit Court of Appeals opinion.
2. Abbott, sales pressure and suicide. NYT article, “Driven to Suicide by Inhuman Pressure to Sell”
3. Airbus under investigation for allegations of bribery to make airliner sales in emerging markets. FT article “Airbus probe poised to shake up Boeing rivalry”.
4. Lily King, finger wagging and calling out the Russian, Yulia Efimova for her history of doping. Inc. article, “Yes, U.S. Swimmer Lily King Was Absolutely Right to Blast Yulia Efimova for Doping”
5. Jay Rosen appearance on Masters of Disasters podcast.
6. Maurice Gilbert’s list of questions every CCO should ask in an interview.
7. Preview Jay's great Weekend Wrap-Up.
8. I highlight the upcoming Red Flag Group webinar on Supply Chain Risk Management.

Aug 11, 2016

A podcast on the compliance profession

Aug 6, 2016

In this episode I visit with Red Flag Group Product Manager, Jared Connors on the step to break down your supply chain into manageable chunks so that you can begin the risk management process. 

Aug 6, 2016

Show notes for Episode 16, for the week ending August 5.

  1. Matthew Stephenson article on the Global Anti-Corruption Blog on JP Morgan sons and daughters FCPA Enforcement Action. My take on this piece on the FCPA Compliance Report.
  2. Financial Times Op-Ed Piece on why the US government must lead the global fight in corruption.
  3. FCPA Blog article on FinCen investigation into beneficial ownership in large real estate transactions involving cash expands.
  4. Bureau van Dijk was made available a replay of its webinar on beneficial ownership issues, featuring Mike Volkov.
  5. From Corporate Counsel – the article “It's Clear Now That Employees Must Cooperate in Probes”. This details a case where a New York court upheld the termination of two Marsh employees for failure to participate in a company internal investigation.
  6. From Above The Law – Catalyst demonstrates how leveraging eDiscovery tools is an effective harness Data analytics to help companies show a commitment compliance in response to the New DOJ FCPA Pilot Program.
  7. Jay recaps his Weekend Report.
  8. I preview my upcoming blog and video podcast series on the Ten Hallmarks of an Effective Compliance Program.
Aug 1, 2016

Show notes for This Week in FCPA-Episode 15, for the week ending July 29, 2016 include:

1) Miller & Chevalier -- FCPA Summer Review 2016 – 7-28-16;

2) NY Law Journal -- Does the New FCPA Leniency Program Threaten Due Process? By Nicholas M. De Feis and Philip C. Patterson from De Feis O'Connell & Rose;

3) Incentivising companies to self-report: Different approaches in different jurisdictions, but the outcomes are broadly the same -- Georgina Jones, Laura Manson and David McCluskey at Taylor Wessing;

4) A video blog from Paul Weiss where A-C & FCPA Pilot Chairs Alex Oh & Farrah Berse look at FCPA Pilot Program - New Guidance for Self-Reporting;

5) From the FCPA Blog – Richard Bistrong interviews Frank Brown, from The Center for International Private Enterprise – (CIPE). Frank speaks about going from Newsweek Bureau Chief in Moscow to now fighting A-C supply chain risks;

6) Mike Volkov, furthers a conversation he had with me earlier in the week about The Power of a Justice Department Declnation;

7) And once more in the breech where myself and Roy Snell go Unfair and Unbalanced on the recent US Open and handling of Dustin Johnson being assessed a 1 stroke penalty;

8) Reports on the LATAM FCPA enforcement action. The can be found at and; and

9) Report on the Petrobras shareholder lawsuit, available at