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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
Dan Chapman talks FCPA investigations
Tom Fox | November 5, 2018
Former CCO Dan Chapman chats with Tom Fox about how to approach an FCPA investigation and come out stronger after remediation.
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The Man From FCPA Blog
Three steps for managing the FCPA risk of distributor compensation
Tom Fox | August 28, 2018
With the Microsoft FCPA investigation as context, there are three things your company can do to manage the risks associated with third-party distributors.
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Tom Fox
D&B shows the right way to handle an FCPA probe
Tom Fox | May 15, 2018
The D&B enforcement action should be studied by every compliance practitioner for tips on preventing an FCPA issue and what to do if you find one.
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Tom Fox
Be careful what you wish for, Corporate America
Tom Fox | March 27, 2018
Businesses might soon regret the Supreme Court’s pro-business Somers decision, which impacts the Dodd-Frank Act anti-retaliation whistleblower provision.
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Tom Fox
Social media basics for the CCO
Tom Fox | February 21, 2018
Building a robust Twitter feed is a must-have in every compliance toolbox. As such, compliance professionals need to brush up on social media.
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Tom Fox
The end of the compliance defense debate
Tom Fox | January 23, 2018
Over the years, there has been a siren’s call for the addition of a compliance defense to the FCPA. It’s time to send the so-called “compliance defense” packing.
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Tom Fox
Aggressive global anti-fraud enforcement to continue
Tom Fox | December 11, 2017
If you thought that enforcement actions like Odebrecht and Vimpelcom were behind us, guess again. They were just the tip of the iceberg. Welcome to the enforcement era.
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Tom Fox
Uber seriously needs some compliance
Tom Fox | December 5, 2017
After all of the misfirings at Uber this year, the company needs to appoint a chief compliance officer, who reports directly to the CEO, and works to change the values while putting in the infrastructure to support the backbone of a best practices compliance program. Sooner, rather than later.
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Tom Fox
Lessons from the Telia FCPA resolution
Tom Fox | October 11, 2017
The largest FCPA resolution on record (so far), at nearly $1 billion, offers plenty of objective lessons for compliance practitioners looking to better understand enforcement trends.
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Tom Fox
Compliance lessons from hurricanes
Tom Fox | September 26, 2017
Recent natural disasters underscore the importance of being prepared, and of practicing crisis response. Compliance officers must do the same for their own hurricane-level crises.
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Tom Fox
Halliburton, the FCPA, and effectiveness
Tom Fox | August 8, 2017
Having a great compliance program means nothing if it exists only on paper. If you want to keep the DoJ and SEC happy, that program must also be demonstrably effective.
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Tom Fox
How Hui Chen prompted an evolution in compliance at the DoJ
Tom Fox | August 1, 2017
Hui Chen’s time as compliance counsel at the DoJ’s Fraud Section was short and eventful and did a lot to move the needle on how the DoJ views corporate compliance programs.
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Tom Fox
Compliance in the 21st Century: Welcome to ComTech
Tom Fox | June 20, 2017
Automation and artificial intelligence stand to increase efficiency in compliance by a quantum leap. But human compliance officers still have a role to play … if they prepare for it now.
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Tom Fox
A farewell to Kara Brockmeyer but her legacy continues
Tom Fox | April 18, 2017
The SEC bids a fond farewell to the head of its Foreign Corrupt Practices Act unit. Tom Fox looks back at Kara Brockmeyer’s illustrious career with the Commission.
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Tom Fox
The hard truths of the SQM enforcement action
Tom Fox | March 21, 2017
The FCPA shows just how far its authority can extend when it comes to companies that blatantly disregard U.S. anti-corruption law.
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Tom Fox
Global anti-corruption enforcement numbers going up
Tom Fox | February 14, 2017
Tom Fox discusses the reasons behind the rise in anti-corruption enforcement and the latest actions by the Securities and Exchange Commission and Department of Justice.
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Tom Fox
How General Cable’s FCPA mess looks to the past and the future
Tom Fox | January 18, 2017
General Cable’s sprawling FCPA enforcement action seemed to go everywhere at once. Tom Fox explains.
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Tom Fox
How JPMorgan Chase avoided prosecution over ‘Sons and Daughters’
Tom Fox | December 13, 2016
At one time, it looked like JPMorgan Chase had landed in fairly hot water with its ‘Sons and Daughters’ bribery scandal. But for every misstep, says Tom Fox, there is a path to freedom.
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Tom Fox
How did GSK obtain a declination?
Bill Coffin | November 22, 2016
If GlaxoSmithKline deserved a declination to prosecute, then the Justice Department needs to provide a better explanation as to why. Tom Fox reports.
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Tom Fox
What’s in your (corporate) wallet?
Tom Fox | November 9, 2016
With the recent scandal at Wells Fargo, The Man From FCPA Tom Fox discusses 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.
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Tom Fox
The FCPA and the fight against terrorism
Tom Fox | October 4, 2016
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.
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Tom Fox
Whistleblower awards and new scrutiny of SEC enforcement
Tom Fox | September 20, 2016
The SEC’s successful whistleblower bounty program is raising some very interesting questions about the future of whistleblowing in general. Tom Fox reports on the agency’s recent enforcement actions.
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Tom Fox
An employee suicide and corporate culture
Tom Fox | August 15, 2016
The Man From FCPA Tom Fox examines the recent suicide of an executive with Abbot Laboratories in India and what happens when the numbers are more important than employees’ well-being.
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Tom Fox
DoJ sends clear signal in the LATAM/LAN FCPA enforcement action
Tom Fox | August 9, 2016
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.
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