Thomas Fox

11152 Westheimer Ste. 742
Houston, TX 77042, United States

  • 832-744-0264

The Whole World Is Watching Mexico In the Fight Against Corruption

I have written about business solutions to legal problems, such as the FCPA, in the energy industry here in Houston. Noted compliance practitioner Scott Killingsworth made similar observations on compliance covenants in…more
| Commercial Law & Contracts, Energy & Utilities, International Law & Trade

What Can You Do When Risk Changes in a Third Party Relationship?

The GlaxoSmithKline PLC (GSK) corruption matter in China continues to reverberate throughout the international business community, inside and outside China. The more I think about the related trial of Peter Humphrey and his…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 80, Interview with the FCPA Professor, Part I [Video]

In this Part I of a two-part interview with the FCPA Professor, we visit about his new book, The Foreign Corrupt Practices Act in a New Era…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Voyager II Launches and The FCPA Professor’s New Book

Many readers of this blog will recall that the Foreign Corrupt Practices Act (FCPA) is 37 years old this year. Perhaps less might remember that also 37 years ago, NASA launched Voyager II, which was an unmanned spacecraft…more
| Commercial Law & Contracts, International Law & Trade

A Surprise in Progressive Rock – FCPA Internal Investigations

The case has a long involved Foreign Corrupt Practices Act (FCPA) history. It involves Panalpina and its customer Shell. David Smyth, in his great blog Cady Bar the Door, reported, in a post entitled “Texas Court of Appeals Has…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

How Can Global Corporations Afford (or Afford Not) To Employ Professional Language Solution Providers

It seems like a daily occurrence that news organizations and blogs (this one included) report that global corporation XYZ, Inc. has run afoul of FCPA statutes somewhere in the world. The next few paragraphs will recount the…more
| Commercial Law & Contracts, International Law & Trade

Lauren Bacall Whistling or How to Structure Customer Due Diligence

Yesterday I wrote about the Foreign Corrupt Practices Act (FCPA) investigation into certain transactions in Venezuela by Derwick Associates (Derwick) and a US company ProEnergy Services (ProEnergy). ProEnergy supplied turbines…more
| Commercial Law & Contracts, International Law & Trade

Na-Nu Na-Nu – Final Report to Ork From Mork – Information from FCPA Inquiries

A Venezuelan company, Derwick Associates (Derwick), are under investigation by the Department of Justice (DOJ) and Manhattan District Attorney’s office. Derwick was reported to have been “awarded hundreds of millions of dollars…more
| Commercial Law & Contracts, Criminal Law, Energy & Utilities, International Law & Trade

Thinking Through Risk Rankings of Third Parties

One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply chain…more
| Commercial Law & Contracts, International Law & Trade

Does Your Company Still Allow Facilitation Payments?

One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes…more
| Commercial Law & Contracts, International Law & Trade

Where to Now St. Peter? – Due Diligence Going Forward in China

Whatever you might think of where his career went, Elton John had some great early stuff. I still rank Tumbleweed Connection right up there as one of my favorite albums of all-time. And while it was packed with some great…more
| Commercial Law & Contracts, Criminal Law, Privacy, International Law & Trade, Science, Computers, & Technology

Nixon Announces Resignation; GSK Just Resigns

Next week, Shanghai’s No. 1 Intermediate People’s Court is scheduled to open a trial against Peter William Humphrey, a 58-year-old British national, and his wife, Yu Yingzeng, a 61-year-old American, on charges of illegally…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade, Science, Computers, & Technology

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of…more
| Commercial Law & Contracts, International Law & Trade

Theme from Shaft and Continuous Improvement of Your Compliance Program, Part I

You should keep track of external and internal events that may cause change to business process, policies and procedures. Some examples are new laws applicable to your business organization and internal events driving changes…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Termination of a Third Party or Breaking Up Should Not Be Hard To Do

One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does Switzer…more
| Commercial Law & Contracts
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