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Thomas Fox

The Drugstore Cowboy And Compliance

One does not have to look very far in the business world to come across the phrase “Know Your Customer.” A company certainly needs to know if an entity that it may sell products or provide services to will pay for those items…more

| Commercial Law & Contracts, Criminal Law, International Law & Trade,...

Tell A Story To Drive Compliance

Sometimes a story will help you understand just what you did not understand. Did you know that the Federal Bureau of Investigation (FBI) launched a formal investigation in 1964 into the supposedly pornographic lyrics of the song…more

| Commercial Law & Contracts

Four Keys To Compliance Leadership

One of the most divisive moments in American history occurred on this date in 1868. On this day the US Senate voted against impeaching President Andrew Johnson thereby acquitting him of having committed “high crimes and…more

| Business Organizations, Commercial Law & Contracts, Labor & Employment...

Scam Artists From Texas And Compliance Risk Management

Billie Sol Estes died yesterday and when it comes to scam artists from the great state of Texas, before there was Allen Stanford and his magical Certificates of Deposits located in his private bank in Antigua, there was Billie…more

| Commercial Law & Contracts, Criminal Law, Finance & Banking, Securities...

What Is Your Compliance Strategy?

Do you have a strategy? The Houston Astros claim to have a strategy that involves being the worst team in baseball for up to the next five years and then magically they will become a winner…more

| Business Organizations, Commercial Law & Contracts, Labor & Employment...

Use Planes, Trains And Automobiles To Get To Compliance Week 2013

To say I am excited would be putting it mildly. Yes that most premier of compliance related conferences is on the short horizon; Compliance Week 2013 is nearly upon us. It will be from May 20-22 at the Mayflower Hotel in…more

| Business Organizations, Commercial Law & Contracts, International Law &...

DPAs And NPAs – Useful Tools To Achieve Compliance

The debate on whether the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution Agreements (NPAs) has become lively again over the past couple of weeks. Last week, there was a panel hosted by the Corporate Crime…more

| Commercial Law & Contracts, Criminal Law, International Law & Trade

Any Special Effects Left For ENRC?

Ray Harryhausen died yesterday. For my money, he was the greatest special effects artist of the 20th century. I absolutely loved his stop motion animation…more

| Criminal Law, International Law & Trade

Do Law Firms Have An In-House Privilege?

There is often a discussion about the retention of outside counsel to lead an investigation of alleged violations of the US Foreign Corrupt Practices Act (FCPA) so that the company may maintain the attorney-client privilege. But…more

| Civil Procedure

And Then There Was One – Willbros Related FCPA Enforcement Continues

Last week, the US Department of Justice (DOJ) announced the sentencing of Paul G. Novak, a former consultant of Willbros International, Inc., a subsidiary of the Houston based Willbros Group, for his role in a conspiracy to pay…more

| Commercial Law & Contracts, Criminal Law, International Law & Trade,...

How Much Due Diligence Is Enough?

Do you really know who you are doing business with in your supply chain? How much due diligence is enough? Should you update your due diligence on a regular basis? How about on a continuous basis? What ethical considerations…more

| Commercial Law & Contracts, Criminal Law, International Law & Trade,...

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