Thomas Fox | Contributing Editor
Thomas Fox is a contributing editor of the FCPA Blog.
Still wondering what the cost of a culture of non-compliance might be? Earlier this month Volkswagen announced it would delay reporting its annual earnings and move back the date of its annual shareholders’ meeting because of uncertainty about the cost of its diesel emissions scandal.
The self destruction of Johnny Manziel in public is sad and has been difficult to watch. He’s been given every opportunity to succeed, along with the tools to deal with his inner demons that seem to bedevil him right up to the present. Many us of hope he can get the assistance he needs to deal with these issues and turn his life and career around.
2015 continued the trend of FCPA enforcement actions brought by the SEC with no parallel DOJ enforcement action. As you might expect, these SEC enforcement actions turned on violations of the FCPA accounting provision, either the books and records or the internal controls provisions.
The Volkswagen emissions-testing scandal continues to provide some of the greatest lessons to be learned for the compliance and ethics practitioner that have been recently seen in any corporate scandal.
In New York I recently saw the theater production of the new David Mamet play China Doll. As you might expect from any Mamet script, it is about rapid-fire language.
One of the more interesting facets of the recent Vicente Eduardo Garcia Foreign Corrupt Practices Act (FCPA) criminal enforcement action was the involvement in the investigation of the Internal Revenue Service – Criminal Investigation.
A trend emerged in the fall of 2014 of FCPA enforcement actions by the SEC but where the Department of Justice either declined to prosecute the company or settled via a non-prosecution agreement.