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Harry Cassin
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Andy Spalding
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Jessica Tillipman
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Richard L. Cassin
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Elizabeth K. Spahn
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Cody Worthington
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Julie DiMauro
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Thomas Fox
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Book Review: Tom Fox’s Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program

Compliance must be thorough, systematic, and highly attentive to detail. But no one ever said it had to be boring. And Tom Fox has proven this yet again. His Doing Compliance provides the most sophisticated and comprehensive compliance guidance available, with a delivery that is witty, lively, and even entertaining.

Doing Compliance uses the pronouncements of the DOJ and SEC as an outline. This is eminently prudent, given those agencies’ discretion over whether, and how, to reward compliance. It then fleshes out that skeleton with commentary, case studies, and anecdotes. Tom integrates principles from sources such as the U.S. Sentencing Guidelines, OECD Good Practices, and the UK Bribery Act, as well as the writings of several leading practitioners and commentators. More than merely providing his own insights (though these would surely suffice), he draws upon diverse sources to produce an inclusive and comprehensive approach. Doing Compliance distills the best thinking of a generation.

But it does so with unmistakable wit and uncommon readability. The writing speaks to common sense, sounds an encouraging and helpful tone, and keeps things lively with occasional references to culture both high and low.  At one point in the Index, successive entries include: “UK Bribery Act,” “UK Ministry of Justice,” “UK Serious Fraud Office,” “US Department of Justice,” and “Van Halen.” (If you’d like to know what the rock band’s notorious intolerance for brown M&Ms can teach us about corporate compliance, see page 63). And should that not be your flavor, well, a nod to the poetry of Elizabeth Barrett Browning shortly follows.

The need for good, careful, practical compliance guidance is undeniable. So too are the financial benefits of adopting best practices. Tom Fox’s book is a good investment. It’s available from Compliance Week here.


Andy Spalding is a senior editor of the FCPA Blog. He is an Assistant Professor at the University of Richmond School of Law.

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