As the third in a triumvirate of releases on compliance programs, the DOJ’s Antitrust Division released its antitrust compliance program guidance in July. This follows the release of the ABC guidance from the DOJ’s Criminal Division in April and the OFAC framework in May. These three documents go a long way in cementing the need for robust and effective compliance for corporations.
In this whitepaper, Tom Fox provides an overview of the Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations and spends time discussing the elements of an effective antitrust compliance program, sentencing considerations and what this new guidance means for anti-corruption and anti-bribery compliance.
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Thomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, risk management and international transactions.
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 tfox@tfoxlaw.com or through his website 
