Thomas Fox has practiced law in Houston for 30 years. He is now an independent consultant, assisting companies with FCPA and compliance issues. He was most recently the general counsel at Drilling Controls Inc., a worldwide oilfield manufacturing and service company. He was involved with compliance investigations, audits, and drafted policies, and he led training on all facets of compliance, including FCPA, export, anti-boycott, and commercial operations training. Fox has the award winning Blogsite, FCPA compliance and ethics blog, and podcast, “The FCPA Compliance and Ethics Report.”
With the recent scandal at Wells Fargo, The Man From FCPA Tom Foxdiscusses the importance of finding out what’s in your corporate wallet, i.e. what information is in your files that could point to issues that might lead to regulatory violations.
Tom Fox looks at the U.S. government’s linking of corruption and terrorism and its intention to use the FCPA as incentive to enact and enforce strong international and domestic anti-corruption and anti-bribery laws.
A recent Foreign Corrupt Practices Act case found LATAM Airlines Group shouldering a heavy burden, paying out approximately $22.2 million in penalties. The significant costs, notes Tom Fox, seems to imply the Justice Department’s FCPA Pilot Program is working.