Thomas Fox

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

  • 832-744-0264

The FCPA Guidance: Still Going Strong at Two

One of the great things about Sunday afternoon is that Mike Volkov posts his Monday blog, when I usually have time to read it when I get the email notification that it is up. Yesterday he wished the Department of Justice’s (DOJ)…more
| Commercial Law & Contracts, International Law & Trade, Mergers & Acquisitions, Securities Law

The Strategic Use of Compliance

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices Act…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA [Video]

In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act…more
| Commercial Law & Contracts, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Chamber of Commerce: Corporations Form the Cornerstone of FCPA Compliance

Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement. You may be surprised to find…more
| Civil Procedure, Commercial Law & Contracts, International Law & Trade

FIFA and Good-Faith Investigations

You know things are getting bad when the Wall Street Journal (WSJ) questions a business’ moral authority. Things certainly cannot be much better when the regulators begin nosing around your own self-indulgence. What happens when…more
| Art, Entertainment, & Sports Law, Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 107 the Bio-Rad FCPA Enforcement [Video]

In this episode, I take a deep dive into the Bio-Rad FCPA enforcement action…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

Opinion Release 14-02: Dis-Linking The Illegal Conduct Going Forward

One of my favorite words in the context of Foreign Corrupt Practices Act (FCPA) enforcement is dis-link. I find it a useful adjective in explaining how certain conduct by a company must be separated from the winning of business…more
| Commercial Law & Contracts, Mergers & Acquisitions, International Law & Trade

Trial Lawyering and FCPA Compliance

As most readers of this blog know, I am a recovering trial lawyer. To this day, some of my best friends are still out there, still teeing it up as trial lawyers. They have an important place in our country’s legal system,…more
| Civil Procedure, International Law & Trade

Atlanta Burns – the Bio-Rad FCPA Enforcement Action – Part III

On this date in 1864, the Union Army phase of the destruction of Atlanta began. While most Southerners credit Union General William T. Sherman with the burning of Atlanta, it was, in reality, Confederate General John Bell Hood…more
| Commercial Law & Contracts, International Law & Trade, Science, Computers, & Technology, Securities Law

fcpa Compliance and Ethics Report-Episode 106-interview with Gini Deitrich [Video]

In this episode I visit with Gini Deitrich, well-known communications and PR expert and author of the recent book Spin Sucks. Gini discusses some of her lessons from this book for the compliance practitioner…more
| Commercial Law & Contracts, Communications & Media Law, Mergers & Acquisitions, International Law & Trade, Securities Law

John Doar and the Bio-Rad FCPA Enforcement Action – Part II

John Doar died yesterday. He was perhaps most famously known for his role as the House Judiciary Committee Chief Counsel during the investigation of and impeachment proceedings against then President Nixon. However, it was his…more
| Commercial Law & Contracts, International Law & Trade, Securities Law

The definitive guide to Corporate Self Reporting

We have aggregated below the SFO guidance on Self Reporting (available on its website on a number of pages) and importantly recent comments from the Director about it. If you are considering Self Reporting as an option we…more
| Commercial Law & Contracts, International Law & Trade

FCPA Compliance and Ethics Report-Episode 105-interview with Barry Vitou [Video]

In this episode I visit with Barry Vitou, one-half of the bribery act.com guys. We discuss the current state of anti-corrruption prosecutions in the UK, the SFO and self-disclosure under the Bribery Act…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law

Gordon Lightfoot, the Edmund Fitzgerald and the Bio-Rad FCPA Settlement, Part I

This month there are two dates that are forever tied together in the annuals of maritime tragedies and great songwriters. November 10 is the 39th anniversary of the sinking of the Great Lakes freighter the SS Edmund Fitzgerald,…more
| Civil Remedies, Commercial Law & Contracts, International Law & Trade, Science, Computers, & Technology, Securities Law

Don’t Collapse in the Wind – Knowledge is Power

On November 7, 1940, high winds buffeted the Tacoma Narrows Bridge leading to its collapse. The first failure came at about 11 a.m., when concrete dropped from the road surface. Just minutes later, a 600-foot section of the…more
| Commercial Law & Contracts, International Law & Trade, Securities Law
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