Thomas Fox

There are a myriad of compliance and ethics conferences across the country each year. I regularly attend and speak at some of these. There are also more regular webinar and local events which may focus on specific topics or…more

An article in the January/February issue of the SCCE magazine, entitled “An ethical corporate culture goes beyond the code”, author Dawn Lomer argues that the unofficial message which a company sends to its employees…more

One of the great things about blogging about the Foreign Corrupt Practices Act (FCPA), UK Bribery Act and ethics and compliance in general, is that practitioners will forward materials to me to review. Not only does this assist…more

In a stunning rebuke of the Department of Justice’s (DOJ) trial strategy, all defendants in the second group of Gun Sting defendants walked out of the federal courthouse, still free. Two defendants were acquitted and the…more

It’s Final Jeopardy and the category is “Compliance”. As your company’s Compliance Officer you are positively salivating at the prospect. So you go all in and bet everything you have on this last…more

In a recent White Paper, entitled “Third Party Essentials: A Reputation/Liability Checkup When Using Third Parties Globally”, authors Marjorie Doyle and Diana Lutz posit that in most foreign business partner…more

At the recent ACI FCPA Boot camp, held in Houston, there was an interesting new angle presented in the enforcement panel. Clarissa Balmaseda, a special agent in charge of Internal Revenue Service (IRS) criminal investigation,…more

Friday, January 27 was the 45th anniversary of the Apollo 1 disaster. As reported by Brian Vastag, in an article in the Washington Post entitled “45 years after America’s first space tragedy, lessons linger”,…more

As compliance programs mature, it is becoming increasing clear that one size does not fit all. Moreover, there may be several different approaches to creating the most effective compliance program for your organization. This…more

One of the areas moving towards being incorporated into a best practices compliance program is that of the supply chain. While many companies have focused significant compliance program effort towards the sales chain, the supply…more

Yesterday, I used some of the wisdom from current CIA Director General David Petraeus to suggest how senior management might move forward with a compliance program. Today I will use a very different individual to help inform…more

Most senior corporate officers are firmly behind their company’s compliance programs, whether based upon the Foreign Corrupt Practices Act (FCPA); the UK Bribery Act or some other anti-corruption or anti-bribery regime…more

Tomorrow Ryan Braun will accept the National League MVP Award. He will accept this award for having a superlative 2012 season; which, as reported by MLB.com, included a “Batting Average of .332 with 33 home runs and 111…more

It is January 19, 2012. What is the significance of this date? Pitchers and catchers report to Spring Training in one month! It is a time of year that even 2011’s worst team in baseball, the 106-loss Houston Astros have a…more

Many commentators looked back at the events of 2011 in the compliance arena and have looked forward into 2012. However, most of the commentators in the United States focused on the US Foreign Corrupt Practices Act for both their…more