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 [email protected] or through his website

Follow this link to see all of his articles.

Goldman may be on the hook for numerous FCPA violations

Goldman Sachs’ dealings with the Libyan Investment Authority have been under scrutiny for a number of years, and the trial finally opened earlier this month in London. The case centers around alleged FCPA violations, the accusation being that Goldman paid handily to influence the LIA’s investments – to the tune of $200 million. A recent resolution in a similar case may come...

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Cooperation and remediation critical for organizations seeking credit from the DOJ

When the DOJ speaks, compliance officers had better listen. At a recent press conference, the DOJ announced a pilot program to encourage companies to self-report FCPA violations and address deficiencies in their compliance programs. Tom Fox explores a key component of the new program and the associated guidance issued by the DOJ: remediation during an FCPA investigation.

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Two corporations paint an interesting picture of corporate compliance

Valeant Pharmaceuticals has come under fire in the past few months for its too-cozy relationship with a third-party vendor. The company, like China’s Anbang Group, also operates under a debt-fueled acquisition model that has left investor confidence shaken of late. After all, business survival will trump ethical practices almost every time.

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When U.S. banks are used in the course of bribing government officials, you have an FCPA violation

The chief executive of the Australian Securities Exchange resigned early last week amid allegations of his involvement in a foreign bribery scandal in which improper payments were made to a Cambodian official. At first blush, it would seem this would be outside the reach of U.S. authorities. Except that payments were made through a U.S. bank.

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One key to an effective compliance program is a reporting system – do you have one?

All effective compliance programs have several factors in common – one characteristic each will undoubtedly have is a system or process by which employees can report issues or concerns about ethics and compliance internally. Just as important as this mechanism is the notion of addressing any issues openly and transparently, giving employees a sense of ownership and participation in the solution.

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Olympus' history of bribery and corruption has left the corporation with a strict CIA

Olympus, the world’s largest manufacturer of optics products, has demonstrated that its culture of corruption is endemic. Having violated the FCPA, the anti-kickback statute and the False Claims Act in a bribery and kickback scandal stretching back several years, the corporation has entered into a strict corporate integrity agreement aimed at ensuring Olympus has an effective anti-corruption compliance program going forward.

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Compliance lessons from Qualcomm’s FCPA enforcement action

Having violated the accounting provisions of the FCPA on several occasions, Qualcomm has been the target of an SEC investigation for some time. Last week the regulatory body concluded its enforcement action against Qualcomm, and there are some key lessons to be learned for the compliance practitioner.

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the VW scandal offers some key lessons for the CCO in crisis management

Volkswagen most certainly made a mess of things when they engineered a device to cheat emissions test, but they’ve bungled their part in the investigation as well. Thanks to the actions of some of the company’s top brass, VW has even further damage to its own reputation. The takeaway for the CCO: look at VW as a clear lesson in what not...

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The best CCOs are strategists

Cars have brakes not just so we can slow down, but also so we can go fast. An effective compliance program should serve the same purpose – not only providing limitations, but enabling the business to thrive – safely. The challenge for the CCO in making this happen, however, is shifting from a tactical mindset to a more strategic one.

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Preventing Employee Fraud with Data Analytics

Without a data analytics solution (or, harder to find, an invoice authority with an eidetic memory), your process for approving T&E expenses and other p-card charges could provide ample opportunity for improper payments to slip through the cracks. With one, however, compliance practitioners can easily detect and prevent this sort of corporate malfeasance.

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