Thomas Fox – Advanced Compliance Solutions

The Sioux at Little Bighorn and Using Risk Going Forward

I recently wrote about the stupidity of General Custer and the defeat of his Calvary at Little Bighorn as a lead in for the failure to adequately assess and then manage risks in a Foreign Corrupt Practices Act (FCPA) compliance…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 175-Debra Bruce on new methods for law firm funding and its implications [Video]

In this episode I visit with Debra Bruce, Principle at Lawyer-Coach. She discusses the recent IPO of the English law firm Gately and alternative funding vehicles available to UK law firms. She explains how these new models will…more
| Commercial Law & Contracts, Finance & Banking, Law Practice Products & Services, Mergers & Acquisitions, Science, Computers, & Technology

The All-Star Game and Tone at the Top

Quite simply, any compliance program starts at the top and flows down throughout the company. Before you arrive at tone in the middle and bottom, it must start with a commitment at the top. All regulatory schemes for…more
| Commercial Law & Contracts, International Law & Trade

Channeling John Steed in Your Tone in the Middle

Today we honor a great English actor from one of the 1960s signature television series. Last week, Patrick Macnee died. He was one-half of the crime-fighting duo on The Avengers. As reported in his New York Times (NYT) obituary,…more
| Commercial Law & Contracts

FCPA Compliance and Ethics Report-Episode 174-Matt Kelly on Dodd-Frank, Uber and Upcoming Compliance Week events [Video]

In this episode I visit with Compliance Week Editor Matt Kelly on how Dodd-Frank is working and affecting financial services, Uber and the recent ruling from the California Labor Board finding one Uber driver an employee and…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Mifune Gets a Star on the Walk of Fame-the Petrobras Scandal Only Gets Worse

(...) I had always thought that the Hollywood Walk of Fame honors actors but it turns out that it honors a great many more performers. For instance, next year will also see names like LL Cool J, Cyndi Lauper, Shirley Caesar,…more
| Criminal Law, Energy & Utilities, Finance & Banking, International Law & Trade, Securities Law

Another Great Bassist Gone and Tone at the Bottom

As most rock aficionados know, rock music is basically a dialogue between the bass guitar and the drums. With this base line set, the lead guitars and keyboards can go soaring off. That was certainly the formula for Yes. But as…more
| Commercial Law & Contracts, Labor & Employment Law, International Law & Trade

FCPA Compliance and Ethics Report-Episode 173-Adam Turteltaub on upcoming SCCE events [Video]

In this episode, I visit with Adam Turteltaub from the SCCE. He discusses some upcoming SCCE academies and other events, including the 2015 Compliance and Ethics Institute, which will be held from Oct. 4-7 in Las Vegas. Adam…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Bristol Palin, Abstinence and the Compliance Defense

Today Bristol Palin informs the debate on the efficacy of a compliance defense to the Foreign Corrupt Practices Act (FCPA). A noted expert on many areas around ethical behavior and family values, Ms. Palin was credited by Mary…more
| Commercial Law & Contracts, International Law & Trade

DOCUMENT, DOCUMENT, AND DOCUMENT Under The Brazilian Clean Company Act

It was only 14 months after Law No. 12.846/2013, Act, entered into force that Brazil finally issued regulations regarding its corporate anti-bribery statute, the so-called Clean Company Act. President Dilma Rousseff issued…more
| Commercial Law & Contracts, International Law & Trade

Custer’s Last Stand and Risk Management

On this day in 1876 one of the greatest failures in risk management took place when Lieutenant Colonel George Armstrong Custer and his entire 7th Cavalry were wiped out at the Battle of the Little Big Horn. Custer had split his…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs [Video]

In this episode I visit with Scott Killingsworth on the recent SEC enforcement action in the SFX matter. In that case, the SEC held the CCO personally liability. We discuss the underlying facts, prior SEC pronouncements the…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was…more
| Commercial Law & Contracts, International Law & Trade

Fraud and the Detection of the Sources for Bribery

In a recent White Paper authored by Peter Smith for OFS Portal, entitled “Procurement and Fraud in the Supply Chain”, where he examined “fraud linked to procurement and supply chain activities.” Smith focuses on where fraud can…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 171-FCPA Enforcement in the Energy Industry [Video]

In this episode I discuss enforcement of the FCPA in the energy industry, it genesis and the business response by the energy industry…more
| Commercial Law & Contracts, Energy & Utilities, Mergers & Acquisitions, International Law & Trade, Securities Law
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