Thomas Fox | Contributing Editor
Thomas Fox is a contributing editor of the FCPA Blog.
Thomas Fox has practiced law in Houston for 30 years. He is now the Compliance Ambassador for the Red Flag Group.
Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”.
His seminal book, “Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program” is widely viewed as one of the top volumes on the nuts and bolts of compliance.
He is one of the top leaders in social media in compliance, blogging, podcasting, writing and speaking across the globe on anti-corruption and anti-bribery compliance programs.
Recent Posts

From 9/11 to Beirut: Once again, corruption leads to terrorism
It started when I read the New York Times piece by multiple reporters, “How a Massive Bomb Came Together in Beirut’s Port.” As I read

The Astros Cheating Scandal: Say It Ain’t So, Joe — Again
Every fan of baseball knows the story. After having been acquitted of taking bribes to throw the 1919 World Series involving the Chicago White Sox

Does FCPA guilty plea signal new trouble for Citgo?
Last week Dick Cassin reported on the FCPA Blog yet another guilty plea in the ever ongoing PDVSA corruption scandal. As Cassin noted, “Jose Manuel Gonzalez Testino (Gonzalez), 49, of Miami, Florida, pleaded guilty in federal court in Houston to one count of conspiracy to violate the Foreign Corrupt Practices Act, one count of violating the FCPA, and one count of failing to report foreign bank accounts.”

The importance of setting a good compliance example
Former U.S. Attorney for the Southern District of New York Preet Bharara (Image from YouTube)Preet Bharara gave the morning keynote at the second day of Compliance Week 2019. It was interesting because rather than a speech he did so with a one-hour Q&A format with Allen & Overy partner Gene Ingoglia facilitating the session through the role of the questioner.

A farewell, with thanks, to President Bush
George Herbert Walker Bush died Friday night. He was the last of the Greatest Generation to serve as President. His administration was the culmination of nearly 40 years of American hegemony which led to the downfall of the Soviet Union.

Tom Fox: What part of ‘zero tolerance’ don’t they understand?
What does it mean to have a zero-tolerance policy for illegal or unethical conduct? Does it mean no as in never, no as in maybe, or no as in we’ll see?

Tom Fox: Venture capital firms like the business of compliance
Want any greater evidence of not only the effectiveness of compliance but its now mandatory nature as a business process going forward? Look no further than the marketplace.

Siemens nominates compliance professional to Board
Compliance professionals should exult as a major global concern, Siemens, has named a CCO to its Board of Directors.

Tom Fox: For Odebrecht, the cost of bribery is still climbing
There is often discussion of the costs of bribery and corruption. Yet one question not often considered is the state of company after it goes through a corruption enforcement action.

Tom Fox: Where are England’s whistleblowers?
The case of Barclays chief Jes Staley attempting to unmask an anonymous whistleblower came to an almost imperceptible and silent ending recently when the UK’s Financial Conduct Authority concluded that Staley’s actions were not done intentionally but apparently with some other, lesser standard.