Companies still struggle mightily when it comes to crafting policies that address the use of facilitation payments. The payments—sometimes called “grease payments”—are small sums given to foreign officials to expedite normal business transactions, such as clearing goods through customs. Some distinguish them from bribes, which are typically meant to entice foreign officials to commit acts […]
Tom Fox
Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in compliance through his best-selling book Upping Your Game. He has 38 other books on the use of AI in compliance and business ethics, leadership including the seminal work, The Compliance Handbook, with its 7th edition coming out in 2025. He is the founder of the award-winning Compliance Podcast Network.
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Justice Department Sheds Light on Charitable Giving and the FCPA
Charitable giving in foreign countries has always been a thorny issue for companies, since they fear that the giving could give way to allegations of violating the Foreign Corrupt Practices Act. This difficulty can be compounded when a company is designing and implementing a full corporate social responsibility strategy. The FCPA forbids companies from making […]
Why the Justice Department Is Shortening Some Monitorships
Editor’s Note: Compliance Week is pleased to introduce our newest columnist, Thomas Fox, a lawyer who specializes in Foreign Corrupt Practices Act compliance and a former general counsel. He will give his perspective on timely and significant FCPA issues that arise in the anti-corruption world. One of the significant developments in Foreign Corrupt Practices Act […]


