The Corruption Files – Details, episodes & analysis

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The Corruption Files

Thomas Fox

Business

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Frequency: 1 episode/36d. Total Eps: 25

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Apple Podcasts

🇨🇦 Canada - management
05/08/2026
#75
🇫🇷 France - management
29/06/2026
#87
🇫🇷 France - management
28/06/2026
#71
🇫🇷 France - management
27/06/2026
#61
🇫🇷 France - management
26/06/2026
#40
🇫🇷 France - management
25/06/2026
#24
🇨🇦 Canada - management
28/04/2025
#63

Spotify

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Score global : 59%

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How One Person Brought Down Barings Bank

Season 2 · Episode 9

Thursday, October 31, 2024 • Duration 24:35

What is stranger than fiction? The stories of worldwide corruption. In this podcast series, co-hosts Tom Fox, the Voice of Compliance and Mike DeBernardis, partner at Hughes Hubbard, discuss some of the most audacious corruption cases in anti-corruption enforcement. More importantly, they will discuss the lessons learned on what your organization can do to prevent running afoul of international anti-bribery laws. In this episode of Season 2, Tom and Mike explore the Barings Bank scandal The focus is on the actions of Nick Leeson, a trader who single-handedly bankrupted the historic institution. The discussion highlights the critical mistakes made by the bank, including a lack of oversight and the dangerous combination of trading and settlement roles. The podast also explores the broader implications for compliance and risk management in financial institutions, emphasizing the importance of segregation of duties and the pressures that can lead to unethical behavior. Key Highlights: The Rise and Fall of Barings Bank The Role of Oversight in Financial Institutions Lessons Learned from the Barings Bank Scandal How does the Fraud Triangle apply? Segregation of Duties-as basic a control as you can have in place Memorable Quotes (all from Mike DeBernardis) “Nick single-handedly bankrupted the oldest merchant bank.” “He was a golden boy trader making tons of money.” “Barings Bank was sold for one pound.” Resources: Mike DeBernardis on LinkedIn Hughes Hubbard & Reed Tom Fox Instagram Facebook YouTube Twitter LinkedIn Texas Tax rate at 80% of 8.25%

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Unmasking Crazy Eddie: Corporate Governance Gone Wrong

Episode 8

Thursday, October 24, 2024 • Duration 18:50

What is stranger than fiction? The stories of worldwide corruption. In this podcast series, co-hosts Tom Fox, the Voice of Compliance and Mike DeBernardis, partner at Hughes Hubbard, discuss some of the most audacious corruption cases in anti-corruption enforcement. More importantly, they will discuss the lessons learned on what your organization can do to prevent running afoul of international anti-bribery laws. In this episode of Season 2, Tom and Mike explore the infamous Crazy Eddie scandal, one of the most audacious corporate frauds in history. The scheme, orchestrated by Eddie Antar and his family during the 1980s and 1990s, involved tax evasion, inventory inflation, and money laundering through a method known as the ‘Panama Pump.’ They defrauded various stakeholders, including customers, bankers, investors, and governmental bodies, ultimately leading to Eddie’s extradition from Israel and imprisonment. This episode dissects the scandal’s rapid unraveling post-IPO, focusing on flawed corporate governance and oversight. By examining the pitfalls of family-controlled businesses and the lack of transparency exemplified by the Crazy Eddie and Boar’s Head Listeria scandals, the hosts underscore the critical importance of checks and balances in corporate structures. Key Highlights: The Audacious Fraud of Crazy Eddie Tax Evasion and Inventory Inflation The Panama Pump Scheme The Whistleblower: Sam Antar Lessons in Corporate Governance Resources: Mike DeBernardis on LinkedIn HughesHubbardReed Tom Fox Instagram Facebook YouTube Twitter LinkedIn Texas Tax rate at 80% of 8.25%

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The Walmart Case

Tuesday, December 6, 2022 • Duration 28:14

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 great opportunity and risk. Thomas emphasizes that extensive remediation and cooperation can bring significant credit. (00:14:14) Michael explains Walmart’s underwhelming conduct. Thomas brings up the congressional investigation, leader exits, and the business implications of publicizing. (00:20:46) Michael shares his advice to avoid Walmart’s case – setting realistic and proper incentives. He also provides hypothetical counsel if he had the chance to work with Walmart when the issue broke out. (00:25:09) Michael highlights the importance of timeliness, engaging with regulators as early as possible, and providing FCPA training when asked. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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Avon China Bribes

Tuesday, November 29, 2022 • Duration 33:03

When beauty company Avon Products Inc. was charged in 2014 with violating the Foreign Corrupt Practices Act (FCPA), due to failure to detect and prevent bribery acts happening in China, they settled for ten times more than the cost they paid for in "gifts." Today, the FCPA investigation and enforcement action still stand as one of the most interesting cases for companies and compliance professionals to learn much from. Tune in to this new episode of The Corruption Files — The Avon China Bribes with Thomas Fox and Michael DeBernardis ▶️ Key points discussed in the episode: [00:05] Tom Fox shares the background facts on such an "insane case," with the investigation almost as interesting and important as the resolution. [00:24] Michael DeBernardis states that Avon China Bribes the grandfather case for a couple of other very similar FCPA cases. [02:16] The internal audit department already identified this issue of paying gifts and recommended FCPA training for the team, which did not push through due to the lack of budget. [02:59] In-fighting or territoriality is not surprisingly uncommon at big companies, leading to compliance and corruption problems. [04:50] Tom cites how in 2012, the government became so frustrated with Avon that they started issuing grand jury subpoenas for individuals. [12:56] A key part of the corporate process is to have systems that talk to each other. And if you don't, the costs can literally be astronomical. [19:25] Avon's $8 million in bribes led to $500 million in pre-settlement costs, $135 million in settlement costs, and $250 million in post-settlement resolutions. [20:50] Tom reminds companies that if there's a potentially high reward, it generally means there's high risk. [24:02] Michael emphasizes that Compliance budgets can be tight, but skipping small training can catch up with you in the long run. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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The Ralph Lauren Bribery Case

Tuesday, November 1, 2022 • Duration 23:42

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 that risk exists in any industry outside the U.S. (00:03:30) Providing an anti-corruption program and employee training got Ralph Lauren ahead of its resolutions and lowered their penalties. It was unclear what monetary value their bribe payments had. (00:08:21) Ensure your employees deeply understand your policies by translating them into different languages. Ralph Lauren took this step and greatly benefited in the case outcomes. (00:11:17) Ralph Lauren’s speedy response and decision for a policy rollout were rewarded with a lenient resolution. This sends a powerful message to regulators that you’re taking the issue seriously. (00:17:15) A tailored risk assessment is helpful. Set up a plan to spot audits and do compliance checks in foreign locations in a certain period. Ralph Lauren’s case is an early model for the corporate enforcement program. (00:21:22) The Ralph Lauren case jumpstarted the corporate enforcement policy. Their proactivity is the biggest takeaway for organizations to apply. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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Parker’s Offshore Oil Drilling

Tuesday, October 18, 2022 • Duration 25:47

There’s no such thing as low risk or no risk. Crafting a web of bribery with a corrupt law firm, a Nigerian fixer, and Panalpina’s hand landed Parker Drilling in hot waters. Tune in as Thomas Fox, and Michael DeBernardis explore the facts of the Parker Drilling case, why overestimating risk is always for the better, how proper conduct impacts sentencing, and why having the right people can impact outcomes. ▶️ Parker’s Offshore Oil Drilling with Thomas Fox and Michael DeBernardis Key points discussed in the episode: (00:00:27) Thomas Fox lays out the basics of the Parker bribery case. (00:06:34) Michael DeBernardis explains the points on the Nigerian agent’s efforts, bribery for unfair business advantage, the lack of due diligence, and fake invoices. (00:10:46) Thomas Fox points out Sarbanes-Oxley as the main driver of compliance, the power of internal controls, the blurry calculations of discounts on the final sentencing, and the impact of Dan Chapman. (00:18:12) Michael DeBernardis highlights how the FCPA system maintains sentencing consistency but still has room for tightening and the nuances of every bribery case. (00:21:58) Thomas Fox underscores the importance of good conduct for the credit and an unanswered question. Michael DeBernardis reaffirms why having the right people in place is beneficial. (00:25:39) Thomas Fox and Michael DeBernardis leave their final thoughts on the case: Have a second set of eyes on dubious wire transfers. Rethink how risk analysis is done. Focus on what you’re doing every step of the way. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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The Goldman Sachs Corruption Case

Tuesday, September 27, 2022 • Duration 27:25

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) Michael DeBernardis explains the successes and failures in compliance. (00:07:32) Thomas Fox points out the suspicious timing of bond offerings, the significant risk involved, why organizations should trust, but verify, and considering the visibility within the organizational structure. (00:14:33) Michael DeBernardis emphasizes why preventative controls like electronic surveillance should be implemented right away and how the Goldman Sachs case proves that improving your company structure is vital. (00:18:35) Thomas Fox and Michael DeBernardis talk about the Monaco Memo and how the Goldman Sachs case perfectly applies the implementation of clawbacks. (00:24:28) Michael DeBernardis encourages companies to publish their general policy statement to prevent future problems. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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Odebrecht/Braskem

Tuesday, September 13, 2022 • Duration 30:23

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, such as the bribery feedback loop and the increasing spending on litigation. Thomas Fox adds that even if you “create bad law, it’s still law.” It has also brought attention to compliance authorities and politicians in Brazil. More companies in other countries were also involved in the scheme. (00:11:58) The bribery scheme was intricately designed to avoid compliance detection. Michael DeBernardis recommends ensuring maximum procurement controls. Petrobras employees benefited mostly in this case. This case has put attention to the importance of having visibility into supply chains. (00:15:57) Michael DeBernardis emphasizes the importance of having appropriate controls to mitigate supply chain risk despite being lower than other aspects of the business. It also exposed the massive scale of corruption. (00:21:54) Michael DeBernardis and Thomas Fox hit home their suggestions to companies: Do a deep risk analysis, get to know your joint venture partners, and any form of defense is helpful. Although the danger is not easy to detect up front, it can help lessen the risk. Also, you should not also close the doors in working with businesses with a little bit of controversy. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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Banks Behaving Badly

Tuesday, August 30, 2022 • Duration 23:21

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. (00:05:10) Thomas Fox examines the compliance lessons to be learned from the Deutsche Bank case. Compliance professionals should consider not only families but friends of commission agents. The worst misconduct can gain reduced penalties when companies cooperate with investigations. Michael adds how Deutsche Bank took corrective action to achieve a significant discount. (00:11:09) Two possible discounts companies may get for compliance are (1) a cooperation discount under the US sentencing guidelines and (2) a discount under the FCPA corporate enforcement policy. (00:12:15) Michael DeBernardis’ standpoint as a lawyer to his clients: be forthcoming, and argumentative when appropriate. (00:13:54) Michael DeBernardis gives a brief background on the SocGen case. (00:19:28) The SocGen case was the first US-France anti-corruption collaboration. Though bribery through agents has been done by others, it’s still an effective dishonest practice. Michael adds that companies have since improved in doing background checks of their agents. ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

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The Sophisticated Conduct of Och-Ziff's African Bribery

Tuesday, August 23, 2022 • Duration 30:41

In 2016, the DOJ and SEC served enforcement action against Och-Ziff Capital Management Group for inappropriate business practices in Africa. It seemed like only yesterday when this successful hedge fund was incriminated in a complex scheme of bribing government officials to maintain and get new business. The settlement was $412 million (and even more for restitution for the victims), making it one of the biggest payments for violating the Foreign Corrupt Practices Act (FCPA). ▶️ The Sophisticated Conduct of Och-Ziff's African Bribery with Tom Fox and Michael DeBernardis Key points discussed in the episode: ✔️ A crisis can breed opportunities for corruption. Even as its red flags became increasingly apparent, the option remained for the Och-Ziff to stop its bribery and illegal action before and even after its activities were discovered. ✔️ Compliance professionals need to have their eyes extra peeled, not simply to vet due-diligence partners but to look deeply into the ongoing business relationships with joint-venture partners. Och-Ziff Subsidiary was involved in corruption issues tied to its mining projects in the Democratic Republic of Congo. What was blatantly amiss was the review and audit necessary to view the joint venture from the compliance perspective. ✔️ Find a joint-venture partner that approaches compliance the same way you do. In handling joint ventures, there is a need for ongoing due diligence — and ongoing management of the relationship beyond due diligence. In the lifecycle of a third-party agent, work starts when the contract is signed, and the joint venture is formed. ✔️ There are various means for auditing available that don’t include turning the place upside down. Here are some good ways to keep an eye on an entity like a joint venture: -Do spot checks on certain transactions -Do sampling from a distance -Make the audit by interviewing the employees to ensure they understand and follow the compliance requirements. ✔️ Remember, it becomes more complicated when you are not in control. Regarding building contractual protections and having strict control, ensure that you find a joint-venture partner that approaches compliance the same way you do. ✔️ Companies have always had audit rights but haven't exercised those rights. It's almost a requirement when making high-risk transactions to not only build in the audit rights but also exercise them. Ask the right questions and gauge whether the third party has been honest in the due diligence process. Many companies get scared off by the idea of the disruption and invasion involved, but that’s what takes away the potential problems and the unnecessary bouts with the SEC and the Department of Justice (which is responsible for enforcing the FCPA). ---------------------------------------------------------------------------- Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com. Texas Tax rate at 80% of 8.25%

The Corruption Files – Details, episodes & analysis

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The Corruption Files – Details, episodes & analysis

Podcast details

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Apple Podcasts

Spotify

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Related Shows Based on Content Similarities

Related Shows Based on Content Similarities

Apple Podcasts

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