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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Day 20 of 31 Days to a More Effective Compliance Program-Responding to Investigative Findings [Video]

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior management attention to the…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

What Level of Due Diligence Should You Perform

Today, I want to take a deep dive and exploration of the levels of due diligence. Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of…more
 /  Commercial Law & Contracts, International Law & Trade

Tribute to Keith Jackson and Breakthrough Strategies in Compliance

Keith Jackson died last week. He was universally recognized as the Voice of College Football and announced college football games for over 40 years. According to his obituary in the New York Times (NYT), Robert A. Iger, the…more
 /  Commercial Law & Contracts, International Law & Trade

Day 18 of 31 Days to a More Effective Compliance Program- Internal Reporting and Triaging Claims [Video]

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the…more
 /  Business Organizations, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

Everything Compliance-Episode 24, the Looking Back to Look Forward Edition [Video]

In this episode, the top compliance roundtable podcast is back with a look at some of the top FCPA, compliance and data privacy/data security issues from 2017 and how they inform what will be the top such issues in 2018. 1…more
 /  Business Organizations, Finance & Banking, Mergers & Acquisitions, International Law & Trade, Securities Law

McKinsey, South Africa and the FCPA

Do you recall the boycott of South Africa from the 1970s and 1980s as a lexicon of the global fight against apartheid? The boycott extended from business to sporting events and everything in between. The campaign was one of the…more
 /  Commercial Law & Contracts, International Law & Trade

Day 17 of 31 Days to a More Effective Compliance Program-Managing Your Third Parties [Video]

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the lifecycle management of third parties, most compliance practitioners understand the need for a…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Rethinking Stakeholder Engagement for the New Millennium

What does stakeholder engagement mean in the 21st century? How has the topic gained such traction over the past few years? What is the role of the compliance professional in stakeholder engagement? How does increased stakeholder…more
 /  Antitrust & Trade Regulation, Business Organizations, International Law & Trade

FCPA Compliance Report-Episode 366 Jonathan Marks on performing and using a root cause analysis [Video]

In this podcast, I visit Jonathan Marks, a partner at Marcum LLP on how to perform a root cause analysis and its uses in the remediation phase of a best practices compliance program. One new and different item was laid out in…more
 /  Business Organizations, Criminal Law, Finance & Banking, International Law & Trade, Securities Law

Compliance Man Goes Global - Episode 8: Tough Questions  [Video]

Welcome to Episode 8 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on tough questions, which Compliance officers need to address. We will explore this…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 16 of 31 Days to a More Effective Compliance Program-the Third-Party Risk Management Process [Video]

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act (FCPA). The Department of Justice Evaluation of Corporate Compliance Programs devotes an entire…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Using a Root Cause Analysis

In my last post, I began considering the Prong of the Evaluation of Corporate Compliance Programs (Evaluation) which was not present in the Ten Hallmarks of an Effective Compliance Program, the root cause analysis…more
 /  Commercial Law & Contracts, International Law & Trade

Day 15 of 31 Days to a More Effective Compliance Program-How Do You Evaluate a Risk Assessment? [Video]

After you complete your risk assessment, you must then translate it into a risk profile, as Rick Messick has noted, to estimate where bribery is likely occur, so prevention efforts will be properly targeted. Ben Locwin…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 14 of 31 Days to a More Effective Compliance Program- Risk Assessments [Video]

One cannot really say enough about risk assessments in the context of an anti-corruption program. Since at least 1999, in the Metcalf & Eddy enforcement action, the DOJ has said that a risk assessment, which measures the…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law

Day 13 of 31 Days to a More Effective Compliance Program [Video]

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions and incentives been…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law
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