Thomas Fox
Compliance Evangelist

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11152 Westheimer
Ste. 742
Houston, TX 77042, United States
Phone: 832-744-0264
Areas of Practice
  • Business Organizations
  • Commercial Law & Contracts
  • Energy & Utilities
  • International Law & Trade
  • Securities Law
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This Week in FCPA-Episode 58, the Declination Edition [Video]

After last week’s guest announcers, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The first Declination of the Session’s Justice Department, Linde gas. 2…more
 /  Criminal Law, Finance & Banking, International Law & Trade, Securities Law

Day 17 Of One Month To Better Investigations and Reporting-Whom To Suspend During an Internal Investigation and De-Confliction [Video]

Who to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Has the FCPA changed the US business culture?

In the early 70’s the Lockheed corruption scandals came into light. Millions of dollars had been paid by the US aircraft corporation to public officials to guarantee contracts for military aircraft in Germany, Italy, Japan,…more
 /  Commercial Law & Contracts, International Law & Trade

The Government Uses Multiple Tools to Fight Corruption

There are multiple ways to deal with an issue which can provide known and unforeseen benefits. Today we celebrate one of those as it was on this day in 1944, that President Franklin Roosevelt signed the GI Bill into existence…more
 /  Commercial Law & Contracts, International Law & Trade

Compliance into the Weeds-Episode 43, the Linde Declination [Video]

In this episode, Matt Kelly and I take a deep dive into the first Declination issued by the DOJ in the era of the Trump Administration, which was issued by the DOJ on June 16, 2017, when it issued a Declination to Linde North…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 16 of One Month to Better Investigations and Report -Privacy Concerns in Investigation [Video]

Prior to the Schrems decision by the European Court of Justice, US based law firms could rely on Safe Harbor to use and analyze information from investigations conducted in Europe. However the Schrems decision and subsequent EU…more
 /  Privacy, International Law & Trade, Science, Computers, & Technology, Securities Law

The PCAOB, Audits, and Compliance - Considerations for the Chief Compliance Officer

I recently had the chance to visit with Joe Howell, the Executive Vice President of Workiva LLC, to discuss, among other things, the function of the Public Companies Accounting Oversight Board (PCAOB) and what role it might play…more
 /  Antitrust & Trade Regulation, Business Organizations, Criminal Law, Finance & Banking

Sgt. Peppers at 50: She’s Leaving Home and Barclays Bank

It has unquestionably been a difficult year for Barclays. Whether any of its former executives will face any jail time for their actions back in the 2008 financial crisis is an open question. As for current bank chief Staley,…more
 /  Antitrust & Trade Regulation, Commercial Law & Contracts, Consumer Protection, Finance & Banking, International Law & Trade

Day 15 of One Month to Better Investigations and Reporting-the Parameters of Privileges [Video]

The concept of privilege in an internal investigation is critical. Two important privileges are the attorney/client privilege and the work product privilege. Unfortunately both are often miss-understood, miss-applied and…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Securities Law

FCPA Compliance Report-Episode 336, James Koukios on Morrison Foerster April Anti-Corruption Report [Video]

In this episode, James Koukios, a partner at Morrison & Foerster returns to discuss the firm's newsletter Top Ten International Anti-Corruption Developments for April 2017. In this episode we highlight the three following…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Unfair and Unbalanced-Episode 20, Roy's Retirement Announcement Edition [Video]

In this episode, I visit with Roy Snell about his recent announcement that he is stepping down as head of the SCCE. We review the current state of the SCCE and how the Roy has seen the compliance evolve from its start after the…more
 /  Finance & Banking, Health, International Law & Trade, Science, Computers, & Technology, Securities Law

Linde in the Republic of Georgia: A Declination and Lessons Learned

Yesterday the FCPA Professor reported the Department of Justice (DOJ) had issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the DOJ…more
 /  Commercial Law & Contracts, International Law & Trade

Day 14 of One Month to Better Investigations and Reporting-Miranda and Internal Investigations [Video]

Must an investigator warn an employee that concealing information from company lawyers conducting an internal FCPA investigation could be a federal crime? Even if the company attorneys handling the investigation provided the now…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Securities Law

The Uber Board Report – Part III: Going Forward

I conclude my blog post series on the Holder Report (Report) to the Board of Directors of Uber Technology, Inc. (Uber) where the Board asked Holder’s law firm, Covington & Burling LLP (Covington), to evaluate three issues: (1)…more
 /  Commercial Law & Contracts

Day 13 of One Month to Better Investigations and Reporting-The Yates Memo and Internal Investigations [Video]

When then Assistant Attorney General Sally Yates, announced the Memo that bears her name, she said the following, “we have revised our policy guidance to require that if a company wants any credit for cooperation, any credit at…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law
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