Thomas Fox

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

  • 832-744-0264

Is Strict Liability Coming to FCPA Enforcement?

I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether such…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Minnie Minoso Broke Barriers; Goodyear Pushes Compliance Forward

Yesterday we celebrated the hard-nosed playing style of Anthony Mason, who recently passed away. Today we honor a true pioneer in professional baseball, Minnie Minoso, or Mr. White Sox. Minoso was the first black Cuban to play…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 137, interview with Loren Steffy [Video]

In this episode I visit with Loren Steffy, former business columnist from the Houston Chronicle…more
| Commercial Law & Contracts, Communications & Media Law, Mergers & Acquisitions, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 136, Joel Borgquist, President of Etik [Video]

In this episode, I visit with Joel Borgquist, President of Etik a company that works to insure transparency in corporate social responsibility programs and assists in conflict resolution…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

The Parameters of the Attorney/Client Privilege and Grinding it out with Anthony Mason

There were two notable deaths over the weekend from the sports world. The first was Anthony Mason and the second Minnie Minoso. Today, we celebrate the life of Anthony Mason. Mason was a part of the Patrick Ewing-led New York…more
| Civil Procedure, Commercial Law & Contracts, Securities Law

Farewell to Mr. Spock and Risk Assessment Under COSO

Leonard Nimoy died last Friday. He will be forever associated with the role of Mr. Spock in the original Star Trek television show which premiered in 1966. The original series ran for only three years but had a full life in…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Gulliver’s Travels, Truth or Fiction?

There was once a man named Gulliver who traveled widely and wrote a book about his adventures called Gulliver’s Tales. During his first voyage, Gulliver is washed ashore after a shipwreck and finds himself a prisoner of a race…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

FCPA Compliance and Ethics Report-Episode 135, Kevin Brady on the process of sales for the compliance practitioner [Video]

In this episode I visit with noted sales process expert Kevin Brady who discussed sales as a process and how the compliance practitioner can use these concepts in communicating the message of compliance to an employee base…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

New Coke and Technological Solutions as a Response to the Economic Downturn

Earlier this week, Donald R. Keough died. He was the leader of Coca-Cola, who pressed for and introduced the infamous New Coke to the world in 1985 and then the return of the original formula just 10 weeks later. Since I was not…more
| Commercial Law & Contracts, International Law & Trade

Doing Less with Less and the Unification of Germany

I am attending the SCCE Utilities and Energy Conference in Houston this week. As usual, the SCCE has put on a great event for the compliance practitioner. This year there is live blogging by Kortney Nordum so there should be…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor [Video]

In this episode, the FCPA Professor and myself continue our exploration of DPAs and NPAs through the recent book review of Judge Rakoff and rejection of a DPAs by Judge Leon in an export control case…more
| Finance & Banking, Mergers & Acquisitions, International Law & Trade

Victory or Death: William Barret Travis and the Obligations of a CCO

Today in 1836, Alamo commander William Barret Travis issued his famous ‘Victory or Death’ plea for reinforcements. It was short so I quote it in full: To the People of Texas & All Americans in the World..…more
| Commercial Law & Contracts, International Law & Trade

Assessing Internal Controls, Part III

In this blog post I conclude my exploration of how you should assess your compliance internal controls using the Committee of Sponsoring Organization of the Treadway Organization (COSO), publication “Internal Controls –…more
| Commercial Law & Contracts, International Law & Trade

Assessing Internal Compliance Controls – Part II

In this blog post I continue my exploration of how you should assess your compliance internal controls using the Committee of Sponsoring Organization of the Treadway Organization (COSO), publication “Internal Controls –…more
| Commercial Law & Contracts, International Law & Trade

Assessing Compliance Internal Controls – Part I

I have recently detailed the COSO 2013 Framework in the context of a best practices compliance regime. However there is one additional step you will need to take after you design and implement your internal controls. That step…more
| Commercial Law & Contracts, International Law & Trade, Securities Law
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