Thomas Fox – Advanced Compliance Solutions

The How Question in Due Diligence

What is satisfactory due diligence under the Foreign Corrupt Practices Act (FCPA)? That question seems to be more important after the Huffington Post’s story on Unaoil and the subsequent release of the Panama Papers. However,…more
| Commercial Law & Contracts, International Law & Trade, Science, Computers, & Technology

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal department…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 255-revising your Code of Conduct [Video]

In this episode, I discuss the considerations going into the revision of your Code of Conduct and how to move forward to do so…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Compliance into the Weeds-Episode 7-meta data for your dashboard [Video]

In this episode Matt Kelly and I take a deep dive into the meta data on the types of information a CCO needs to feed into a compliance dashboard. Go from asking, “What do I want to know about?”; to asking, “What types of…more
| Commercial Law & Contracts, International Law & Trade, Mergers & Acquisitions, Science, Computers, & Technology, Securities Law

CCO Independence, Authority and Resources as Indicia of an Effective Compliance Program

At the Opening Session of Compliance Week 2016, Stephen L. Cohen, Associate Director of Enforcement, Securities and Exchange Commission (SEC) and Andrew Weissmann, Chief of the Department of Justice (DOJ) Criminal Division’s…more
| Commercial Law & Contracts, International Law & Trade

Up Close and Personal: Individual CCO Liability – Part II

Yesterday I began an exploration of the potential individual liability of a Chief Compliance Officer (CCO) based upon the Financial Industry Regulatory Authority (FINRA) enforcement action against Raymond James Inc. and its…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

Up Close and Personal: Individual CCO Liability – Part I

A horse is a horse, of course, of course, and no one can talk to a horse, of course. That is, of course, unless the horse is the famous Mister Ed. Those lines were the opening verse to the theme song of the TV…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly impact…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Joe Howell on the PCAOB, Audits and Compliance – Part III

Today, I continue my exploration with Joe Howell about the Public Accounting Oversight Board (PCAOB), its scrutiny of public company auditors and how its work impacts the corporate compliance function. Yesterday, I ended with a…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 254 use of social media in a best practices compliance program [Video]

In this episode I consider how to use the tools of social media in a compliance program. I discuss how CCO Louis Sapirman at Dun and Bradstreet has incorporated the tools of social media into his company's compliance efforts…more
| Communications & Media Law, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Joe Howell on the PCAOB, Audits and Compliance – Part II

Today we have Part II of my exploration with Joe Howell about the PCAOB and how its work with public company auditors impacts anti-corruption compliance. I asked Howell about auditor rotation and what it means. Howell…more
| Commercial Law & Contracts, Mergers & Acquisitions

FCPA Compliance and Ethics Report-Episode 253-Loren Steffy reflects on the Enron, the trials of Ken Lay and Jeff Skilling and corporate culture [Video]

In this episode, I visit with Loren Steffy who covered the Enron trial for the Houston Chronicle. He reflects on the lasting impact of the Enron scandal and how it continues to resonate today…more
| Communications & Media Law, Criminal Law, Finance & Banking, Mergers & Acquisitions, Securities Law

Joe Howell on the PCAOB, Audits and Compliance – Part I

I recently had the chance to visit with Joe Howell, the Executive Vice President (EVP) of Workiva LLC. Howell has been the Chief Financial Officer (CFO) of a number of public companies, mostly in the technology space, and some…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

GHBER Tribute to Jay Martin

This Thursday 19th May, the Greater Houston Business and Ethics Roundtable (GHBER) will hold its first Ethics and Compliance Awards Dinner in honor of the 20-year anniversary of the organization’s founding. We will award the…more
| Commercial Law & Contracts, International Law & Trade

The FCPA and SOX and Internal Controls – Twin Sons of a Different Mother?

What is the interplay of two different pieces of legislation enacted almost 25 years apart in response to widely different crisis? In the case of the Foreign Corrupt Practices Act (FCPA) and Sarbanes-Oxley Act (SOX) quite a bit…more
| Commercial Law & Contracts, International Law & Trade, Securities Law
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