Welcome to another episode of The Corruption Files!  Thomas Fox and Michael DeBernardis discuss questionable hiring practices from JP Morgan, Credit Suisse, and Bank of New York (BNY) Mellon in employing relatives of high-profile clients to gain favor. They also discuss how companies can find a middle ground in hiring families, why Hiring can be a high-risk area, preventative questions to avoid a violation and the significance of internal control and documentation. ▶️ Hiring in the Financial Space with Thomas Fox and Michael DeBernardis Key points discussed in the episode: ✔️ Thomas F ..read more

Establishing trust can greatly affect the outcome of a case. Thomas Fox and Michael DeBernardis talk about ABB’s 2022 bribery case in South Africa, how self-disclosure benefits any situation, the DOJ’s approach on cracking down recidivists, choosing the right people for your team, and being wary of waivers. ▶️ The ABB Settlement with Thomas Fox and Michael DeBernardis  Key points discussed in the episode: (00:00:29) Thomas lays out the facts of the ABB settlement. Michael points out the DOJ’s plans for penalizing recidivists and ABB’s biggest compliance misstep. (00:07:07) Thomas emphasiz ..read more

Tom Fox and Michael DeBernardis shed light on the bribery schemes highlighted in the cases of Eli Lilly, Fresenius, and Teva and present the prosecutorial investigation, the questionable donations and expenses, preventative measures for companies to implement, and practicing due diligence to minimize risk. ▶️ Uncovering the Hidden Schemes in Pharma with Thomas Fox and Michael DeBernardis Key points discussed in the episode: ✔️ Thomas Fox introduces the cases involving Eli Lilly, Fresenius, and Teva. ✔️ Michael DeBernardis breaks down the DOJ and SEC’s investigative process in uncovering El ..read more

Rapid expansion presents great opportunity and great risk. Thomas Fox and Michael DeBernardis go deep into the Walmart bribery case, why immediate cooperation matters, tips for companies to prevent similar problems, the best course of action when working internationally, and projecting risk regardless of industry. ▶️ The Walmart Case with Thomas Fox and Michael DeBernardis  Key points discussed in the episode: (00:02:36) Thomas lays out the facts of the Walmart case. Michael points out how prevention could have saved millions of investigation costs. (00:09:50) Rapid expansion presents gre ..read more

Thomas Fox and Michael DeBernardis discuss energy cases considered FCPA violations, highlighting Panalpina Settlement Day, the uncovered bribery methods, and its implications on the future of compliance, the written policies, and the solutions to commerce and transactions in higher-risk jurisdictions.  ▶️ Energy Violations and the Panalpina Settlements with Thomas Fox and Michael DeBernardis Key points discussed in the episode: ✔️ Tom Fox introduces the cases involving Shell, Transocean, Tidewater, Pride International, and Noble. ✔️ Michael DeBernardis describes the company’s methods ..read more

This is Tom Fox. I'd like to welcome you to an exciting new podcast series that I'm premiering on the Compliance Podcast Network, The Corruption Files, together with my co-host Thomas Fox and Michael DeBernardis, an artist partner at Hughes Hubbard & Reed LLP. We're going to be taking a look at some of the top corruption enforcement actions in the United States and beyond.  In our first five episodes, we're going to focus on some key industries inside the United States, which had important FCPA actions. We're going to focus on the background of each of the enforcement actions.  W ..read more

If you’re aggressive with your response, you’ll be rewarded. Thomas Fox and Michael DeBernardis break down the facts and lessons learned in the Ralph Lauren bribery case in Argentina. Discover why anti-corruption programs and worker training matter, how speedy cooperation improves resolution leniency, and why organizations shouldn’t be complacent when it comes to risk. ▶️ The Ralph Lauren Bribery Case with Thomas Fox and Michael DeBernardis Key points discussed in the episode: (00:00:35) Thomas Fox gives an overview of the Ralph Lauren case. Michael DeBernardis highlights how this case shows t ..read more

Risk is never static, but dynamic. The Goldman Sachs case has proven that playing with fire will always get you burned. Listen in as Thomas Fox and Michael DeBernardis dissect the rights and wrongs of the situation, why probing deeper into red flags is a must, the importance of setting off preventative controls right away, and why companies should publicly show their general policy statement. ▶️ The Goldman Sachs Corruption Case with Thomas Fox and Michael DeBernardis  Key points discussed in the episode: (00:00:20) Thomas Fox gives a brief background on the Goldman Sachs case. (00:03:02 ..read more

Brazilian petroleum company Petrobras caught itself in an intricate bribery scheme involving top construction corporations like Odebrecht and Braskem and political parties. Thomas Fox and Michael DeBernardis lay out the facts and share their insights on what lessons other companies can learn and practice to avoid similar compliance troubles. ▶️ Odebrecht/Braskem with Thomas Fox and Michael DeBernardis  Key points discussed in the episode: (00:00:32) Thomas Fox gives a brief background on the Petrobras-Odebrecht-Braskem case. (00:03:35) Michael DeBernardis clarifies more facts on the case ..read more

Thomas Fox and Michael DeBernardis discuss the dubious bribery cases of financial institutions, specifically Deutsche Bank, Credit Suisse, and Societe Generale (SocGen), that utilized commission agents of significant political power. They also talk about why compliance committees should look closer into the backgrounds of company agents and how the Deutsche Bank kickstarted France’s fight against corruption. ▶️ Banks Behaving Badly with Thomas Fox and Michael DeBernardis Key points discussed in the episode: (00:00:36) Michael DeBernardis gives a brief background on the Deutsche Bank case. (00 ..read more