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 [email protected] or through his website www.tfoxlaw.com.
Follow this link to see all of his articles.
As the third in a triumvirate of releases on compliance programs, the DOJ's Antitrust Division released its antitrust compliance program guidance in July. This follows the release of the ABC guidance from the DOJ's Criminal Division in April and the OFAC framework in May. These three documents go a long way in cementing the need for robust and effective compliance for corporations....
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Corporate ownership in China isn’t always crystal clear. One safe approach: just assume the business is state owned. Tom Fox discusses FCPA guidance for companies with business dealings in China. How important is due diligence on those with whom you do business? Why does it matter if a company is owned or controlled by a foreign government or a political party member...
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Published by Compliance Week and Available Now on Amazon Tom Fox, the Compliance Evangelist, is one of the leading writers, thinkers and commentators on the Nuts and Bolts of compliance. His always practical advice is now collated the most unique compliance handbook available, The Compliance Handbook. The handbook incorporates the most recent pronouncement and guidance from the Department of Justice, including 2017’s...
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Those bemoaning the lack of Foreign Corrupt Practices Act (FCPA) enforcement activity can cease. With the Dun & Bradstreet Inc. (D&B) declination in April and May’s enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic), U.S. regulators at the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have roared back with not only significant enforcement actions, but more importantly for the compliance...
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In a truly extraordinary article in the New York Times (NYT), columnist Thomas L. Freidman opened the article on his interview with Crown Prince Mohammed bin Salman (MBS) with the following, “I never thought I’d live long enough to write this sentence: The most significant reform process underway anywhere in the Middle East today is in Saudi Arabia. Yes, you read that right....
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Compliance Leadership Tips from the Surgeon General Tom Fox recounts some lessons learned from a recent New York Times profile of Surgeon General Nadja Y. West. Her guidance is widely applicable to leaders across industries and specialties, but some of her insights are real nuggets of wisdom for the compliance practitioner in particular. For me, September 11 is the most solemn day in...
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One Question Answered, Others Left Open In a recent Supreme Court decision, the nation’s highest court limits the SEC’s power to recover ill-gotten gains. It’s a seeming victory for Wall Street and a blow to regulatory authorities’ enforcement powers. But, as Tom Fox discusses, this decision raises more questions than it answers. This article was republished with permission from Tom Fox’s FCPA Compliance...
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Overcoming Key Obstacles Does your organization have a “speak up” culture? Is it widely understood that there won’t be retaliation against someone who does? Corporate culture is defined from the top down, and this is especially true when it comes to ethics. To encourage ethical behavior, leaders must be sure they’re setting the right tone at the top. By: Tom Fox This...
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The Case for a Compliance SME Just as it wouldn’t be wise to have a tax attorney negotiate a bribery settlement, you don’t want someone with minimal compliance experience serving as your board’s subject matter expert on compliance. The DOJ has continually stressed the importance of having a compliance expert on the board, and it will only be a matter of time...
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With due diligence, the expectation is that when risks are identified, something is done about them. Knowledge of a potential threat and mitigation of that problem are two very different things. The NFL could learn a thing or two about proper due diligence; its handling of recent domestic abuse among its players indicates the league doesn’t take abuse as seriously as it...
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The latest massive corporate scandal has been brought to you by Wells Fargo. After news broke that thousands of Wells Fargo employees have been creating fraudulent customer accounts for years, the bank has all but lost the public’s trust. The CEO blames rogue employees, but the real culprit here is a rotten culture. Tom Fox suggests that the board holds its share...
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As much as Volkswagen wants us to believe it, corruption never happens in a vacuum. As VW squirms under the weight of a DOJ investigation into their decade-long emissions scandal, it’s becoming clear that the initial claim of engineers acting solo won’t hold water. It’s another instance of corruption underscoring the myth of the rogue employee.
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