IMG_3310It has been a slow week with no Foreign Corrupt Practices Act (FCPA) enforcement actions announced, although the Wall Street Journal (WSJ) did report that one with JPMorgan Chase is imminent. I thought I would provide a potpourri of upcoming issues and events for your consideration this Friday.

Managing Supply Chain Risk – Webinar Series Continues

Imagine you are sitting in your compliance department office and you get a call from the Chief Compliance Officer (CCO) who tells you that he wants you to put together a Supply Chain (SC) risk management program. (Or worse, you are an Associate General Counsel (AGC) and he receives a similar call from the General Counsel (GC).) You do some quick checking and you discover that you have some 60,000 vendors within your company’s SC database. Where do you begin?

Fortunately for you, Jared Connors, Chris Sidnik and myself from the Red Flag Group are presenting a four-part webinar series on Supply Chain risk management. On Thursday, August 18 at 10 CDT we will be presenting our second installment on issues around Supply Chain risk management, with Part II – Breaking your supply chain into manageable pieces for a risk based approach.

We detail some of the keys to creating a manageable approach to SC risk management programs, assess some of the outside pressures your company might face and lay out a four step process to not only obtain the information but also action steps you can take for remediation. You can register for the webinar at the Red Flag Group website, which can be found by clicking here. The webinar is free. I hope you can join us.

Riding to Fight Cancer

As many readers know I used to be a serious cyclist, which alas I am no longer. However my friend Doug Cornelius, the Founder and Editor of the Compliance Building, has taken up the mantel and is riding this week in the Pan Mass Challenge. Doug is riding to help raise money in the fight against cancer and for his friends and family who have suffered from this disease. The Pan Mass Challenge ride is 192 miles over two days from Sturbridge to Provincetown. If Doug’s meets his fundraising goal, he promises to ride a full Century (100 miles) on a third day of riding. Trust me when I say, you have to be in great cycling shape to ride not only 192 miles in two days but maybe a little crazy to tack on another 100 miles for good measure on the next day. Monies raised from the ride will go to the Dana-Farber Cancer Institute. I hope you will join me in supporting Doug and consider a donation to help him meet his fundraising goal. You can check out Doug’s page by clicking here.

Leadership Lessons Podcasts

As you may know I have founded a podcast on business leadership, entitled 12 O’Clock High. As with most lawyers, such concepts were not taught where I went to law school, are still sadly lacking in most law school curriculum and many in-house types are lacking in formal training on leadership. This becomes more acute when lawyers move into the compliance profession, which is more akin to business process role than a straight legal function. Additionally, as the Department of Justice (DOJ) made clear when they announced their Pilot Program for FCPA enforcement going forward, they will be assessing whether compliance practitioners are given the opportunity to advance in a corporation, in both disciplines and functions other than compliance. This makes learning about leadership all the more critical for those who did not study it in an academic setting.

I have two recent podcasts, which I want to highlight for your consideration. The first deals with the leadership failures demonstrated by the English governing class before, during and after the Brexit vote and most importantly, what lessons the business leader can take away. You can listen to the episode, Leadership Lessons from Brexit, by clicking here. In my most recent episode, I consider the leadership lessons from Abraham Lincoln, tailored for the business professional. You can listen to this episode, by clicking here. You can also check out the podcasts on iTunes.

This Week in FCPA

Looking for the most authoritative source of the week’s comings and goings in all things FCPA, compliance and ethics related. Or, in the words of Monty Python, are you simply looking for something completely different. Either way, you should check out the weekly blab session that Mr. Translations, aka Jay Rosen, and myself, have each Friday morning. This Friday we have a special early edition at 8:30 AM CDT, as our usual time is 9 AM CDT. If you cannot make it that early, I cross-post each blab session on Facebook, YouTube and as a podcast on the FCPA Compliance Report so there are plenty of avenues for you to enjoy our unique take on the week’s events and issues. To check out the blab session live, click here.

A Sneak Peak at Increasing Your Practical Knowledge of FCPA Compliance

I am working on a project I have wanted to put out there for some time, which is a short podcast series on the Ten Hallmarks of an Effective Compliance Program, as articulated in the FCPA Guidance. Over the last two weeks of August, I will post a podcast and corresponding blog post for each Hallmark. If you are a reader or listener (or both) and want a quick review on what constitutes a best practices compliance program or if you are new to the compliance realm and want to hear from the Nuts and Bolts guy, this will be a great series for you to check out.


This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at

© Thomas R. Fox, 2016