Thomas Fox

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 or through his website

Follow this link to see all of his articles.

evolution of light bulbs on red background

Because leadership dynamics are changing, so too should the old “command and control” function of compliance. Tom Fox offers guidance to help CCOs adapt to the changing times. Given the paucity of leadership coming out of Washington during this crisis, I thought it would be a ripe time to consider some innovations in compliance leadership. While many compliance departments may have begun...

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illuminated Huawei logo

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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the complete compliance handbook

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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Crash Landing: Lessons From the Panasonic FCPA Enforcement

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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building ceiling

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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closeup of office landline with "call me" written on desk

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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smiling woman cupping her ear to hear better

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. The indictments earlier this month of executives...

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silhouette of lecturer delivering presentation on compliance

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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Knowing of a risk alone won’t facilitate compliance

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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Lack of ethics leads to loss of trust at Wells Fargo

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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