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Tom Fox
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.”
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Tom Fox
First British DPA Provides Much to Ponder
Tom Fox | December 8, 2015
It has finally come to pass: the first deferred-prosecution agreement under the U.K. Bribery Act. From the role of judicial oversight (greater than that in the United States) to the final statement of facts (much greater than that in the United States), the settlement with ICBC Standard Bank is full of lessons for compliance officers to weigh. Inside, our columnist Tom Fox works through the DPA and starts the pondering. More inside.
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Tom Fox
For FCPA Compliance, Don’t Forget the Internal Controls
Tom Fox | October 21, 2014
They have been there all along, hiding in plain sight: the Foreign Corrupt Practices Act requirements for internal controls. In its latest FCPA guidance, the SEC and Justice Department emphasized the importance of internal controls in effective compliance, which they backed up with two recent enforcement actions. Inside, columnist Tom Fox offers some ideas on how to ensure good internal controls are in place for anti-bribery and anti-corruption compliance.
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