FCPAméricas Blog
Archive for Tom Fox category:
More Wisdom from Tom Fox
12.13.2011
At last week’s World Compliance FCPA Summit 2011 in Houston, TX, U.S. FCPA compliance attorney Tom Fox offered important points of wisdom. “Document, Document, Document.” The bedrock components of an adequate FCPA compliance program are well known. Every deferred prosecution agreement since Panalpina has included an Attachment C outlining basic requirements (see, e.g., Attachment C […]
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No “Tone From the Top”? What’s Compliance to Do?
11.17.2011
The job of a general counsel or anti-corruption compliance officer in managing a company’s compliance efforts is hard enough. It gets even harder when he or she lacks the “tone from the top” support from senior management. In these situations, what is an officer to do? What lessons on ethical leadership can he or she […]
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What FCPA Enforcement Is Thinking in 2011
11.14.2011
The annual National Conference on the U.S. Foreign Corrupt Practices Act (FCPA) in Washington, DC, hosted by American Conference Institute, is always a unique opportunity to hear from FCPA enforcement officials about what they are currently thinking. This year’s meeting did not disappoint. Held last week, it included noteworthy statements, some of which are provided […]
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Is the FCPA Working? Three Dispatches from Latin America
10.03.2011
In his August 12, 2011 article entitled “Recent Disclosures Raise Many FCPA Questions,” the FCPA Professor Mike Koehler asks whether increased FCPA enforcement has done anything to deter future violations. This question is timely, especially given that the FCPA is under fire by major organizations (such as the U.S. Chamber of Commerce) for the burdens […]