FCPAméricas Blog
Archive for Tom Fox category:
Wal-Mart’s Bribery in Mexico (Part 2: Insights into Specific Corruption Risks)
4.25.2012
A lot has been discussed about Wal-Mart over the last three days since the New York Times’ bribery story broke. FCPAméricas offered its initial thoughts in Part 1 of this series. The story will no doubt continue. Enforcement officials will eventually act. The ways in which the New York Times obtained such detailed information will […]
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The Biomet Case: Lessons from the latest FCPA settlement involving Latin America
3.30.2012
Earlier this week, a former colleague and skilled attorney, Lisa Prager, offered thoughts on compliance priorities in her article for Forbes entitled, “FCPA Compliance: Don’t Blow Your Budget Just Yet.” She advises companies to implement straightforward compliance programs and to target compliance efforts to the areas of business posing the highest corruption risks. Companies need […]
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The Ideal Compliance Team
3.13.2012
I have previously written about The School for Ethics and Global Leadership (SEGL) in Washington, DC, a high school semester boarding program that I co-founded in 2009 whose mission is to prepare our country’s future leaders to be ethically strong and internationally aware. I recently attended one of the school’s signature classroom lessons. The topic […]
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An FCPAméricas Status Update
3.02.2012
Tomorrow marks the five-month anniversary of the launch of the FCPAméricas Blog. Remember the first post on October 3, 2011? Is the FCPA Working? Three Dispatches from Latin America. Now, almost 40 blog posts in, I am taking stock. The following are a few things I have learned so far, and some thoughts about potential […]
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Third Party Red Flags and Latin America
1.03.2012
Looking back at FCPA enforcement actions in 2011 that involved Latin America, all but one included risk created “indirectly” by third parties. And that one, Tyson Foods, involved payments to spouses of Mexican officials, a potentially odd twist on the concept of “third party risk.” The kind of third parties used in these cases included […]