Thomas Fox

Ruth Rendell and Developing Better Compliance Solutions

Ruth Rendell died this past weekend. Along with Patricia Cornwell, she was one of the two greatest mystery writers for the past couple of decades. I thoroughly enjoyed her books which, as her New York Times (NYT) obituary said,…more
| Commercial Law & Contracts, International Law & Trade

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose [Video]

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

King Arthur Week – The Quest for the Holy Grail and Compliance Defense – Part V

We conclude our Arthurian themed week with the Holy Grail, which has fired the imagination of artists for millennia. What was the Holy Grail? According to Professor Dorsey Armstrong in her Teaching Company lecture series,…more
| Commercial Law & Contracts, International Law & Trade

King Arthur Week – The Green Knight and the Protection of Whistleblowers – Part IV

We continue our King Arthur themed week with an exploration of one of the most interesting characters in the Arthur canon, The Green Knight, so called because his skin and clothes are green. The meaning of his greenness has…more
| Administrative Law, Civil Rights, Commercial Law & Contracts, Labor & Employment Law, Securities Law

King Arthur Week – The Round Table and Compliance Professionals and Lawyers as Whistleblowers – Part III

Today we use King Arthur’s Round Table as the entry into our topic. The Round Table is the famous table around which he and his Knights congregated. Its shape implies that everyone who sits there has equal status. Wace, who…more
| Civil Rights, Commercial Law & Contracts, Labor & Employment Law, International Law & Trade, Securities Law

King Arthur Week – the Pentecostal Oath and Code of Conduct – Part II

The foundational document of any Foreign Corrupt Practices Act (FCPA) compliance program is its Code of Conduct. This requirement has long been memorialized in the US Sentencing Guidelines, which contain seven basic compliance…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 154-Compliance Leadership-Persuasion, Influence, Tools & Tips, Skills and Tips [Video]

In this episode, I discuss some of the tools which a compliance practitioner or CCO can use to further compliance in an organization…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Taxation

King Arthur Week, King Arthur and Leadership – Part I

I have been studying the legend of King Arthur and thought it would be good idea to have a week of blog posts around the legend of King Arthur, the Roundtable and his knights. Today I begin with King Arthur and some leadership…more
| Commercial Law & Contracts, International Law & Trade

The Easter Rebellion and Petrobras’ $17 Billion Write Down

On this day, 99 years ago the Easter Rebellion began. If there is one event that is seared into history as a turning point for Irish independence from Britain, it was the Easter Rebellion. England had finally granted Home Rule…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade

FCPA Compliance and Ethics Report-Episode 153-Doing Compliance in an Economic Downturn [Video]

The energy industry is in turmoil from the drop in the price of oil from $100 down to around $50 per barrel. Many energy companies have laid off up to 30% of their workforce. What can you do from the compliance perspective when…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Interview with James Koukios

Ed. Note-today I continue my series of interviews with people prominent in the FCPA space. Today is James Koukios, formerly a Manager in the DOJ’s FCPA unit, who recently went into private practice at Morrison & Foerster…more
| Commercial Law & Contracts, International Law & Trade

Austin City Limits and Asking Questions to Boost Your Compliance Program

Bill Arhos died recently. While his name is not a household word across the country, his progeny certainly is for he was the founder of the longest running live musical show on PBS television Austin City Limits. As was noted in…more
| Commercial Law & Contracts, International Law & Trade

The Petrobras Scandal and Corruption of Political Parties Under the FCPA

When does bribery and corruption move from a business issue to a political issue to a national issue? Why should US companies be held to the gold standard of anti-corruption laws? Should the US government even care if US…more
| Commercial Law & Contracts, Elections & Politics, International Law & Trade

The Intersection of the FCPA, TI-CPI and Tax Appeals in Brazil

The Transparency International-Corruptions Perceptions Index (TI-CPI) is released each year in November. The TI-CPI rates Brazil as 69th out of 175 countries on its index, coming in with a score of 43 out of 100. I wonder if TI…more
| Commercial Law & Contracts, International Law & Trade, Taxation

The Passing of Günter Grass and Compliance Week 2015 Is Near

Günter Grass died this week. The contradictions that made up post-war Germany were wrapped up in him as well as any other single person I know anything about. He was a Nobel Prize winner for literature, who, it was revealed late…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law
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