Thomas Fox – FCPA Compliance and Risk Management Attorney and Consultant
Thomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, risk management and international transactions.
He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously Division Counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division, which included the logging, directional drilling and drill bit business units.
Tom attended undergraduate school at the University of Texas, graduate school at Michigan State University and law school at the University of Michigan.
Tom writes and speaks nationally and internationally on a wide variety of topics, ranging from FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi-national US companies, insurance coverage issues and protection of trade secrets.
Thomas Fox can be contacted via email at firstname.lastname@example.org or through his website www.tfoxlaw.com.
Follow this link to see all of his articles. Tom also writes a regular column on CCI called Compliance Nuts & Bolts.
Mr. Spock and his pursuit of logic inform today’s blog post. Every compliance practitioner is aware of the need for a risk assessment in any best practices compliance program; whether that program is based on the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act or some other compliance law or regime.
This might be the time that you consider a technological solution to help manage your FCPA anti-corruption compliance program going forward. It may be that you can come out running a more effective program, yet ultimately spend less money because you do not have to replace employees aid off during your company’s initial response to the downturn.
U.S. franchisors doing business abroad come into contact with officials of foreign governments fairly frequently - if not once they're up and running, then certainly during the startup process. Each interaction presents an opportunity for an FCPA violation. And if and when a misdeed comes to pass, who's ultimately liable? The individual with boots on the ...
No matter how much anti-bribery/anti-corruption training your company provides, no matter how diligent your efforts to prevent compliance violations, it's possible that you'll have a "5 percenter" in your ranks -- someone who will lie, cheat and steal anyway. In order to steer clear of serious compliance infractions, you may need to reassess your screening and hiring processes.