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 firstname.lastname@example.org or through his website www.tfoxlaw.com.
Follow this link to see all of his articles.
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 →
Olympus, the world’s largest manufacturer of optics products, has demonstrated that its culture of corruption is endemic. Having violated the FCPA, the anti-kickback statute and the False Claims Act in a bribery and kickback scandal stretching back several years, the corporation has entered into a strict corporate integrity agreement aimed at ensuring Olympus has an effective anti-corruption compliance program going forward.Read more →
Having violated the accounting provisions of the FCPA on several occasions, Qualcomm has been the target of an SEC investigation for some time. Last week the regulatory body concluded its enforcement action against Qualcomm, and there are some key lessons to be learned for the compliance practitioner.Read more →
Volkswagen most certainly made a mess of things when they engineered a device to cheat emissions test, but they’ve bungled their part in the investigation as well. Thanks to the actions of some of the company’s top brass, VW has even further damage to its own reputation. The takeaway for the CCO: look at VW as a clear lesson in what not to do.Read more →
Cars have brakes not just so we can slow down, but also so we can go fast. An effective compliance program should serve the same purpose – not only providing limitations, but enabling the business to thrive – safely. The challenge for the CCO in making this happen, however, is shifting from a tactical mindset to a more strategic one.Read more →
One of the latest scandals to hit the world of sports is performance enhancement in cyclocross. The medium in this case isn’t pharmaceutical in nature, but technological – a miniature motor designed to give the cyclist an artificial push. This instance of fraud is like any other: it didn’t happen in a vacuum, and there’s little chance of the deception being the work of a lone wolf.Read more →