Thomas Fox – Compliance Evangelist

Ten Hallmarks of an Effective Compliance Program-Hallmark 4 [Video]

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 4-risk assessments…more
| Communications & Media Law, International Law & Trade, Science, Computers, & Technology, Securities Law

Hallmark 4- Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Ten Hallmarks of an Effective Compliance Program-Hallmark 3 [Video]

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 3 - Oversight, Autonomy and Resources…more
| Finance & Banking, International Law & Trade, Mergers & Acquisitions, Science, Computers, & Technology, Securities Law

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Ten Hallmarks of an Effective Compliance Program-Hallmark 2 [Video]

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 2-Code of Conduct and Compliance Policies and…more
| Business Organizations, Mergers & Acquisitions, International Law & Trade, Science, Computers, & Technology, Securities Law

Hallmark 1 – Commitment from Senior Management and a Clearly Articulated Policy Against Corruption

Over the next two weeks I will be revisiting the Ten Hallmarks of an Effective Compliance program, as laid out in the 2012 A Resource Guide to the U.S. Foreign Corrupt Practices Act ( FCPA Guidance) authored by the Criminal…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

This Week in FCPA-Episode 18, the Olympics edition [Video]

Show notes for week ending August 19, 2016: 1. Key Energy FCPA enforcement action. 2. More Och-Ziff FCPA news as its “Fixer” is arrested for FCPA violations. 3. EU’s to Olympic committee arrested and charged with ticket…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Ten Hallmarks of an Effective Compliance Program-Hallmark 1 [Video]

In this series, I review the Ten Hallmarks of an Effective Compliance Program. This episode premiers Hallmark No. 1…more
| Business Organizations, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

FCPA Compliance Report-Episode 274, Scott Lane on an holistic approach to third party management [Video]

In this episode, I visit with Red Flag Group CEO Scott Lane on a holistic approach to third part risk management…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

FCPA Compliance Report-Episode 273 [Video]

In this episode, I visit with Marc Bohn, Counsel at Miller & Chevalier on the recent 11th circuit opinion limiting the SOL on profit disgorgement claims to 5 years and the IRS tax letter holding payments for profit disgorgement…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

The End of the Wild West

Many say the Wild West ended on this day in 1895 when John Wesley Hardin was gunned down in El Paso by the town’s sheriff. Hardin was a legendary gun slinger who is purported to have gunned down over 40 men in his career. He was…more
| Commercial Law & Contracts, Environmental Law, International Law & Trade

Compliance is a Business

Compliance is a business. That statement should not come as a shock or even a surprise to anyone who has worked in the corporate world. Every part of a business should work towards doing business. Yet many compliance…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Key Energy FCPA Resolution – Part III

This week I have been exploring the Key Energy, Inc. (Key Energy) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to consider the actions taken by Key Energy to obtain the very good resolution the company…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade, Securities Law

Farewell to R2D2 and Key Energy FCPA Resolution – Part II

Yesterday I began a what I thought would be a two-part series on the Key Energy, Inc. (Key Energy) Foreign Corrupt Practices Act (FCPA) enforcement action. However (and as usual), I got carried away so today I will review the…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade
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Areas of Practice
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  • Energy & Utilities
  • International Law & Trade
  • Securities Law
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