Thomas Fox

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

  • 832-744-0264

Compliance Lessons from Santa

We interrupt our Avon blog post series to announce that a large man, with a white beard and red suit, will visit all on Wednesday evening. In honor of Christmas I want to write about some of Santa’s business lessons, which I…more
| Commercial Law & Contracts

Alstom Joins Santa’s Naughty List – In a Very Big Way

The North Pole for Foreign Corrupt Practices Act (FCPA) enforcement action announcements seems to have temporarily moved south for the month of December. Last week there was the final announcement of the long-standing Avon FCPA…more
| Administrative Law, Commercial Law & Contracts, Criminal Law, International Law & Trade, Securities Law

The Avon FCPA Settlement, Part I

It is finally done. The long awaited Avon Foreign Corrupt Practices Act (FCPA) enforcement action is on the books. I would say what a long, strange trip it has been but that does not really seem to capture everything that went…more
| Commercial Law & Contracts, International Law & Trade

Winter Begins in Valley Forge and the FCPA Professor Teaches in Miami

Today we celebrate one of the seminal turnarounds in US history for on this day in 1777, George Washington lead his beleaguered troops into winter quarters at Valley Forge, Pennsylvania. At that point in time, things could…more
| Commercial Law & Contracts, Elections & Politics, International Law & Trade

Ty Cobb and the Compliance Performance Appraisal Review

Today we celebrate greatness, in the form of one of the greatest baseball players ever, with the anniversary of the birthday of Ty Cobb. Coming up to the majors as a center fielder for the Detroit Tigers in 1905, he emerged in…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom [Video]

In this episode Compliance Week editor Matt Kelly and I discuss the COSO 2013 Framework implementation and its changes from the prior Framework. We also discuss the recent Bruker Corp & Dallas Airmotive FCPA enforcement actions…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, Intellectual Property, Securities Law

Scrooge and Corporate Settlement Agreements

Although there seems to be a difference in the precise publication date between the online reference sites This Day in History and Wikipedia, today we celebrate the Charles Dickens’ work A Christmas Carol, which both sites…more
| Commercial Law & Contracts, International Law & Trade

The Eve of Destruction and Tone at the Top – You Are Who Say You Are

In 1965 the single Eve of Destruction was released. It was written by an 18 year old named Phil Sloan and was sung by former member of the New Christie Minstrels named Barry McGuire. To top it off, it was produced by Lou Adler…more
| Commercial Law & Contracts, Labor & Employment Law, International Law & Trade

Hiring and Promotion in Compliance – Wait for Great

The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated. I come from a HR background and practiced labor law early in my career…more
| Commercial Law & Contracts, Labor & Employment Law, International Law & Trade

The FCPA Compliance and Ethics Report-Episode 114-Doing Compliance, The Book [Video]

In this episode, I discuss my recently released book, Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Seamus Heaney and Compliance With a Seat at the Table

I have long been fascinated with the Irish poet Seamus Heaney. I came to know him thought his 1999 translation of Beowulf. While I was aware that he had been awarded the 1995 Nobel Prize for Literature, I did not know his work…more
| Commercial Law & Contracts, International Law & Trade

On Compliance Leadership: From Edward VIII to LeBron James

On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the…more
| Commercial Law & Contracts, International Law & Trade

The Nobel Prize and FCPA Enforcement Going Forward

One hundred and 13 years ago on this date, the first Nobel Prizes were awarded in Stockholm, Sweden, in the fields of physics, chemistry, medicine, literature, and peace. The ceremony came on the fifth anniversary of the death…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Bobby Keys, the Rolling Stones and Establishing Trust

Bobby Keys died last week. What you probably did not know was that Keys was a Texan so we get to claim him. He was the saxophonist for the Rolling Stones and a number of other serious rockers…more
| Commercial Law & Contracts, International Law & Trade

DPAs and NPAs – Powerful Tools in the Fight Against Corruption

As readers of this blog know the FCPA Professor and I usually look at the same Foreign Corrupt Practices Act (FCPA) enforcement action, item or remark and see different things. Sometimes we even hear the same thing and come away…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade, Securities Law
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