Thomas Fox

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

FCPA Compliance and Ethics Report-Episode 151-Glenn Lammi of the Washington Legal Foundation [Video]

In this episode I visit with Glenn Lammi of the Washington Legal Foundation who discusses the work of the WFL…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Consumer Protection and Your Business

You’ve been hearing for a while now that the regulatory environment has been changing, and you follow the Consumer Financial Protection Bureau (“CFPB”) alerts to see if this new regulator will be looking at your type of business…more
| Commercial Law & Contracts, Finance & Banking, Privacy, Consumer Protection, Science, Computers, & Technology

FCPA Compliance and Ethics Report-Episode 150-Tanya Otterstein-Liehs on the Process of Fitness [Video]

In this episode, I visit with Canadian fitness guru Tanya Otterstein-Liehs on her process approach to fitness, the need for a positive attitude in any job you perform and how she has been able to create a large clientele using…more
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Five Step Process for Transaction and Continuous Controls Monitoring

Most Chief Compliance Officers (CCOs) and compliance practitioners understand the need for transaction monitoring. Whether it be as a part of your overall monitoring of third parties, employees, or to test the overall…more
| Commercial Law & Contracts, International Law & Trade

Lincoln Assassinated and HSBC’s Continued Self-Inflicted Woes

HSBC continues to stay in the news, unfortunately largely for the wrong reasons in the realm of anti-corruption, facilitating tax evasion and money laundering. In an article in the New York Times (NYT), entitled “HSBC Is Deemed…more
| Commercial Law & Contracts, Criminal Law, Finance & Banking, International Law & Trade

Brazilian Corruption Scandal Expands Past Petrobras – Is a FCPA Country Sweep Next?

The Brazilian corruption scandal took a new turn last week, when the Brazilian government announced that it was investigating the country’s health ministry and the state-owned bank Caixa Econômica Federal (Caixa). As reported by…more
| Commercial Law & Contracts, International Law & Trade

International Anti-Corruption Enforcement Efforts

While the US Foreign Corrupt Practices Act (FCPA) is still the most widely recognized and enforcement anti-bribery and anti-corruption law across the globe, there have been a number of initiatives which will lead directly to…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 149-Patrick Taylor of Oversight Systems on developments in transaction monitoring [Video]

In this episode I visit with Patrick Taylor, CEO of Oversight Systems on some of the newest developments in tools to facilitate transaction monitoring…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law
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