FCPAméricas Blog
Archive for Tom Fox category:
Colombia Now Subject to OECD Anti-Bribery Working Group Review (and what this means)
2.07.2013
Colombia joined the OECD Anti-Bribery Convention on January 19, 2013. This should have significant effects on the country. Just ask Mexico, Brazil, the UK, and Canada. These countries, and others, have been inspired to improve their foreign bribery laws due to, more than anything, the periodic compliance reviews conducted by the OECD Working Group on […]
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Latin America’s Top FCPA Enforcement Activity in 2012
1.15.2013
FCPA enforcement in the past year left no doubt that Latin America, especially the dynamic economies of countries like Brazil and Mexico, continues to present considerable corruption risks to the companies and businesspeople operating there. Here is a recap of key developments in 2012: Wal-Mart (Mexico, Brazil): Growing FCPA Awareness. The New York Times reporting […]
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The FCPA, Iran Sanctions, and Compliance Convergence
10.18.2012
My friends Howard Sklar and Tom Fox are fond of talking about “compliance convergence.” The idea is that, in an age where compliance expectations are created by a wide range of legal regimes – everything from anti-corruption to export controls, anti-trust to environmental laws – companies can structure their compliance mechanisms efficiently to address a […]
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Why Tyco Got Off Easy
10.03.2012
We do not know for sure why Tyco received only a non-prosecution agreement (NPA) instead of a deferred prosecution agreement (DPA), or how it avoided a monitor. But the treatment is notable. Even the FCPA Professor, often critical of the approach of FCPA enforcement, appears to have found the results commendable. He calls the action […]
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Three Perspectives on M&A FCPA Due Diligence
7.17.2012
A general counsel of a private equity firm recently told me that it is helpful for him to consider FCPA compliance issues through the lenses of the various actors involved. In that spirit, FCPAméricas offers three perspectives on M&A FCPA due diligence – from the FCPA enforcer, the acquirer, and the target. For background on […]