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
Tom Fox on VW: The cost of a ‘strategy of delay and obfuscation’
Still wondering what the cost of a culture of non-compliance might be? Earlier this month Volkswagen announced it would delay reporting its annual earnings and move back the date of its annual shareholders’ meeting because of uncertainty about the cost of its diesel emissions scandal.
Tom Fox: Johnny Football and Accountability in Compliance
The self destruction of Johnny Manziel in public is sad and has been difficult to watch. He’s been given every opportunity to succeed, along with the tools to deal with his inner demons that seem to bedevil him right up to the present. Many us of hope he can get the assistance he needs to deal with these issues and turn his life and career around.
Fox’s top five SEC actions in 2015 (with Tom’s practice hints)
2015 continued the trend of FCPA enforcement actions brought by the SEC with no parallel DOJ enforcement action. As you might expect, these SEC enforcement actions turned on violations of the FCPA accounting provision, either the books and records or the internal controls provisions.
VW’s answer to culture issues: Get rid of the corporate Airbus
The Volkswagen emissions-testing scandal continues to provide some of the greatest lessons to be learned for the compliance and ethics practitioner that have been recently seen in any corporate scandal.
Tom Fox: The FCPA has a starring role . . . . on Broadway!
In New York I recently saw the theater production of the new David Mamet play China Doll. As you might expect from any Mamet script, it is about rapid-fire language.
Tom Fox: The Petrobras scandal reaches into Texas
For those who think the U.S. government shouldn’t be concerned with the Petrobras scandal, allegations of bribery and corruption have reached the great state of Texas.
Tom Fox on VW and the Yates Memo
Coming on the heels of the GM settlement for defective ignition switches where there were no prosecutions of individuals, the VW scandal will be a test for the Department of Justice and its new policy announced a few days ago with the Yates Memo.
Tom Fox: IRS involvement in Garcia FCPA enforcement action signals more risks
One of the more interesting facets of the recent Vicente Eduardo Garcia Foreign Corrupt Practices Act (FCPA) criminal enforcement action was the involvement in the investigation of the Internal Revenue Service – Criminal Investigation.
Compliance Week 2015: Tom Fox liked the vibe
Compliance Week 2015 has ended. This was the tenth anniversary of the yearly conference and in many ways I found it to be the best one yet.
Tom Fox: Disgorgement could become a remedy for FCPA strict liability
A trend emerged in the fall of 2014 of FCPA enforcement actions by the SEC but where the Department of Justice either declined to prosecute the company or settled via a non-prosecution agreement.