Thomas Fox

11152 Westheimer Ste. 742
Houston, TX 77042, United States

  • 832-744-0264

FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I [Video]

In this episode 88 of the FCPA Compliance and Ethics Report, I visit with noted internal controls expert Henry Mixon on the types of internal controls needed for third parties in a FCPA compliance program…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

To the NFL – Show More Than Ethics, Show Some Humanity

Just a short ten days ago I wrote about how thrilled I was that the National Football League’s (NFL) 95th season was upon us and pro football was about to begin. But in the intervening 10 days, it is as if the very football gods…more
| Art, Entertainment, & Sports Law, Commercial Law & Contracts

Use of HR in Your FCPA Compliance Program [Video]

In this episode of the FCPA Compliance and Ethics Report, I discuss how HR can help to facilitate your compliance program…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 87, what are internal controls, Part II [Video]

In this Part II of What Are Internal Controls? I continue my discussion with noted expert Henry Mixon on the basics of internal controls in a best practices FCPA compliance program…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

King Arthur’s Roundtable – The CCO as Chief Collaboration Officer

Many commentators such as Donna Boehme and Mike Volkov often talk about what is required for the position of Chief Compliance Officer (CCO), both in terms of corporate support and skills as a leader of a company’s compliance…more
| Commercial Law & Contracts

What Are Internal Controls, Part I [Video]

In this episode of the FCPA Compliance and Ethics Report, I begin a series on internal controls, with noted practitioner Henry Mixon. This is the first part of a two part episode on the basics of what are internal controls…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Management of Corruption Risks – Business Lessons from GSK

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made it abundantly clear over the past several years that companies should assess their risk and then manage their own risks…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Board of Directors and FCPA Oversight – An Internal Control Under SOX, Part II

In Part I of this two-part post regarding a Board of Director’s Role in Foreign Corrupt Practices Act (FCPA) oversight from the internal controls perspective, I reviewed how a Board might have independent liability for its…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Board of Directors and FCPA Oversight – An Internal Control Under SOX, Part I

Today we begin by honoring the political process and a politician extraordinaire for on this day in 1836, Sam Houston was elected as the first President of the Republic of Texas. One of the most interesting characters from the…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Pro Football and the FCPA Professor

As readers of this blog will know, I often use sports to discuss the nuts and bolts of Foreign Corrupt Practices Act (FCPA) compliance. So it was gratifying to see the FCPA Professor use sports in some of his writings…more
| Commercial Law & Contracts, International Law & Trade

Language as a Long Term Compliance Strategy

I constantly rely on Jay Rosen and his team at Merrill Brink for translation and other language related services in the compliance portion of my work. (Yes I do practice law and compliance for a living; I blog for gratis.)…more
| Commercial Law & Contracts, International Law & Trade

Spin Sucks-Communications Tips for the Compliance Professional

One of my favorite social media acquaintances is Gini Dietrich, the founder and Chief Executive Officer (CEO) of Arment Dietrich Inc. Not only does she bring one of the freshest voices to what might arguably be called ‘one of…more
| Commercial Law & Contracts

Extraordinary Rendition and Ripples From the Chinese Corruption Investigations

As many of you know, I am a recovering trial lawyer. So I was very interested when I received a book for review by Paul Batista, entitled Extraordinary Rendition. Not only is Batista a practicing trial lawyer specializing in…more
| Commercial Law & Contracts, Energy & Utilities, Finance & Banking, International Law & Trade

Risk Assessments - the Cornerstone of Your Compliance Program, Part III

Today, I conclude a three-part series on risk assessments in your Foreign Corrupt Practices Act (FCPA) or UK Bribery Act anti-corruption compliance program. I previously reviewed some of the risks that you need to assess and how…more
| Commercial Law & Contracts, International Law & Trade

Risk Assessments-the Cornerstone of Your Compliance Program, Part II

One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different approaches in his article “Practical Suggestions for Conducting Risk Assessments.”…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade
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