He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously Division Counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division, which included the logging, directional drilling and drill bit business units.
Tom attended undergraduate school at the University of Texas, graduate school at Michigan State University and law school at the University of Michigan.
Tom writes and speaks nationally and internationally on a wide variety of topics, ranging from FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi-national US companies, insurance coverage issues and protection of trade secrets.
Thomas Fox can be contacted via email at email@example.com or through his website www.tfoxlaw.com.
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With due diligence, the expectation is that when risks are identified, something is done about them. Knowledge of a potential threat and mitigation of that problem are two very different things. The NFL could learn a thing or two about proper due diligence; its handling of recent domestic abuse among its players indicates the league doesn’t take abuse as seriously as it ought.Read more →
The latest massive corporate scandal has been brought to you by Wells Fargo. After news broke that thousands of Wells Fargo employees have been creating fraudulent customer accounts for years, the bank has all but lost the public’s trust. The CEO blames rogue employees, but the real culprit here is a rotten culture. Tom Fox suggests that the board holds its share of the responsibility.Read more →
As much as Volkswagen wants us to believe it, corruption never happens in a vacuum. As VW squirms under the weight of a DOJ investigation into their decade-long emissions scandal, it’s becoming clear that the initial claim of engineers acting solo won’t hold water. It’s another instance of corruption underscoring the myth of the rogue employee.Read more →
It is a sad reality that many whistleblowers are subject to serious repercussions for shedding light on corporate wrongdoing. For the want of support from compliance leadership, their acts of public service are rewarded with lawsuits and threats. The compliance function must work to insulate whistleblowers from retaliation at the very least.Read more →
Goldman Sachs’ dealings with the Libyan Investment Authority have been under scrutiny for a number of years, and the trial finally opened earlier this month in London. The case centers around alleged FCPA violations, the accusation being that Goldman paid handily to influence the LIA’s investments – to the tune of $200 million. A recent resolution in a similar case may come into play, however …Read more →
Both pieces of legislation aim to minimize wrongdoing – one to prevent corruption abroad, the other to minimize financial fraud. Both focus on robust internal controls as part of the solution. The FCPA lays the burden of managing internal controls on the organization as a whole, but under SOX, the duties clearly fall to the executive officers.Read more →
When the DOJ speaks, compliance officers had better listen. At a recent press conference, the DOJ announced a pilot program to encourage companies to self-report FCPA violations and address deficiencies in their compliance programs. Tom Fox explores a key component of the new program and the associated guidance issued by the DOJ: remediation during an FCPA investigation.Read more →
Valeant Pharmaceuticals has come under fire in the past few months for its too-cozy relationship with a third-party vendor. The company, like China’s Anbang Group, also operates under a debt-fueled acquisition model that has left investor confidence shaken of late. After all, business survival will trump ethical practices almost every time.Read more →
The chief executive of the Australian Securities Exchange resigned early last week amid allegations of his involvement in a foreign bribery scandal in which improper payments were made to a Cambodian official. At first blush, it would seem this would be outside the reach of U.S. authorities. Except that payments were made through a U.S. bank.Read more →
All effective compliance programs have several factors in common – one characteristic each will undoubtedly have is a system or process by which employees can report issues or concerns about ethics and compliance internally. Just as important as this mechanism is the notion of addressing any issues openly and transparently, giving employees a sense of ownership and participation in the solution.Read more →