Legal News

Most compliance professionals understand the need to discipline employees who may have violated ethics and compliance programs or otherwise engaged in bribery and corruption. However, many Chief Compliance Officers (CCOs) and compliance practitioners...By: Thomas Fox

In today’s edition of Daily Compliance News: 1. Citgo 6 rearrested in Venezuela. (HoustonChronicle) 2. Credit Suisse CEO fired for spying on subordinates. (FT) 3. Top CitiGroup trader fired for stealing food from Canteen. (FT) 4. Corporate CEO...By: Thomas Fox

In today’s edition of Sunday Book Review we pay tribute to Roger Kahn with a review of the following books: 1. The Boys of Summer 2. The Roger Khan Reader 3. The Era, 1947-1957: When the Yankees, the Giants, and the Dodgers Ruled the World 4. Good...By: Thomas Fox

In today’s edition of Daily Compliance News: 1. Another Airbus casualty. (FreeMalaysiaToday) 2. Undercover informant in NCAA scandal avoids jail time. (Bloomberg) 3. Ex-Pimco CEO gets 9-month jail term. (Reuters) 4. DOJ drops anti-trust inquiry into...By: Thomas Fox

One of the key points that representatives of the DOJ and Securities and Exchange Commission (SEC) have continually raised when discussing any best practices compliance program. The 2012 FCPA Guidance is clear that there should be incentives for not...By: Thomas Fox

We have been getting accountability all wrong in the compliance profession. It's not a set of tasks - it's a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance Tom Fox and Sam Silverstein...By: Thomas Fox

The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key indicia for an ethical...By: Thomas Fox

The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key indicia for an ethical...By: Thomas Fox

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level of due diligence and then...By: Thomas Fox

One new and different item laid out in the 2017 Evaluation, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance, was the performance of a root cause analysis for any compliance violation which may led to a...By: Thomas Fox