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.
Acts of criminal misconduct are - almost without fail - carried out either by an individual or a group of individuals, so it stands to reason that the DOJ would focus its efforts on individual prosecutions rather than to bring charges against the company itself. The company's participation in any resulting investigation is expected, but it should tread ...
There's more than one way to skin a cat - whether we're talking about putting on an incredible rock show or running an effective compliance program. Keep in mind, though, that however your compliance program is fleshed out, if and when an investigation begins, the DOJ will look not only at its components, but also how it's been ...
Those seeking to abuse the system will find a way to do it, so it's imperative that companies implement strong internal controls and then continually strive to strengthen them further. Make no mistake, detecting and preventing FCPA violations takes discipline, but initiatives and activities undertaken with discipline generally pay off, don't they?
Take a closer look at GSK's failures in China and they seem so obvious. There are some key lessons for professionals in the compliance space to learn from their significant oversights--namely lacking controls, deficiencies in auditing and a breakdown in monitoring. We should be mindful of the warnings implicit in the GSK enforcement actions.