02/14/2012 04:30:00 PM EST
Lessons Learned on Compliance and Ethics
When my daughter was 7 she wrote and published her first
book. When I asked her how she did it, she replied "Dad, it's easy to write a
book, you just sit down and do it." I thought about that sage wisdom for many
years before I sat down and started writing this blog. While I did not set out
to write a book about compliance when I began blogging, I did hope to
bring some of the things I have learned about the nuts and bolts of compliance
to other practitioners. After several years of writing this blog, one of my
mentors in this field, Dick Cassin, who writes the FCPA Blog, suggested I collate some of my
pieces and publish a book. So there are now two published authors in the Fox
In this volume I have collected some of my posts which I
think will help guide you in your own journey through the world of
anti-corruption and anti-bribery compliance. I have broken the book down
into the following chapters:
Some Thoughts on Best Practices -
This chapter charts some of the evolving standards of a best practices compliance
program, with articles on the thoughts of Department of Justice (DOJ)
representatives; guidelines from the US Sentencing Commission; standards from
the OECD; and comments on the UK Bribery Act.
The Nuts and Bolts of Compliance -
This chapter includes articles regarding the 'How To' of compliance inside a
corporation. As any in-house practitioner knows, the practice of law
inside of a corporation is very different from private practice. I try to bring
an in-house perspective and provide guidance on how to perform the
day-to-day work of implementing, assessing and enhancing a compliance program,
inside a corporation.
Investigations, Enforcement Actions and Legal
Issues - In this chapter I discuss ongoing
investigations, enforcement actions which resulted in Deferred or
Non-Prosecution Agreements and legal issues. From this discussion you, the
reader, should be able to understand the Department of Justice's most current
thinking on compliance issues.
Summing It All Up -
This chapter highlights some of the top enforcement actions and compliance
issues which companies have faced. These articles provide more than just 'tea
leaf' readings of where enforcement is going across the globe and will provide
to you solid guidance in your compliance program going forward.
I have included the full text of the Foreign Corrupt
Practices Act (FCPA) as well as the Department of Justice's "Lay
Person's Guide to the FCPA".
I know that you will find this book useful in your
compliance practice and I hope that you will purchase it. It is available for
the very reasonable price of $19.99 and you can order it on Amazon.com by
Visit the FCPA Compliance and Ethics Blog,
hosted by Thomas Fox, for more commentary on 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.
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