Recent Posts

Taking the Rolls Out for a Spin? Maybe You Should Avoid Brazil
Posted on 10 Mar 2015 by Thomas Fox

Just as the GlaxoSmithKline PLC (GSK) case in China heralded a new day in international anti-corruption enforcement, the Petrobras case may be equally important going forward. The scope and breadth of the investigation is truly becoming worldwide. Last... Read More

Earl Scruggs: Banjo, Bluegrass and the Fight against Corruption and Bribery
Posted on 3 Apr 2012 by Thomas Fox

Last Thursday, Earl Scruggs died. He was one of the musician's most responsible for my development in learning about, and appreciating, different styles of music. For musicians, he basically invented and then popularized the 3 finger picking style... Read More

Kroll and Compliance Week Survey Anti-Bribery and Anti-Corruption
Posted on 30 May 2013 by Thomas Fox

Not many people realize that the US has elected one president who served as a prisoner of war. That man was Andrew Jackson, who was captured by the British during the Revolutionary War. Now, can you name the American President who killed another man... Read More

Wolfsberg Anti-Corruption Guidance
Posted on 19 Oct 2011 by Thomas Fox

In a recently released White Paper by the Wolfsberg Group, entitled " Wolfsberg Anti-Corruption Guidance " , a group of internal banks, together with Transparency Internal and the Basel Institute on Governance, issued guidance on anti-corruption... Read More

Brazilian Corruption Scandal Expands Past Petrobras – Is a FCPA Country Sweep Next?
Posted on 13 Apr 2015 by Thomas Fox

The Brazilian corruption scandal took a new turn last week, when the Brazilian government announced that it was investigating the country’s health ministry and the state-owned bank Caixa Econômica Federal (Caixa). As reported by Rogerio Jelmayer... Read More

The Easter Rebellion and Petrobras’ $17 Billion Write Down
Posted on 27 Apr 2015 by Thomas Fox

Ninety-nine years ago Friday the Easter Rebellion began. If there is one event that is seared into history as a turning point for Irish independence from Britain, it was the Easter Rebellion. England had finally granted Home Rule to Ireland in 1914 but... Read More

International Anti-Corruption Enforcement Efforts
Posted on 10 Apr 2015 by Thomas Fox

While the US Foreign Corrupt Practices Act (FCPA) is still the most widely recognized and enforcement anti-bribery and anti-corruption law across the globe, there have been a number of initiatives which will lead directly to greater anti-bribery and anti... Read More

Bone-Headed Moves on the Football Field and Idiotic Statements About Corruption
Posted on 13 Feb 2015 by Thomas Fox

“ Three things can happen when you throw the football, and two of them are bad .” That football truism (allegedly) came from former Texas Longhorn head coach Darrell Royal. While he intoned it in a different era, Pete Carroll and his Seattle... Read More

Transparency International Guidance on Anti-Corruption and Anti-Bribery Due Diligence for M&A Transactions – Part I
Posted on 3 Oct 2011 by Thomas Fox

Transparency International (TI) recently released, in draft form for consultation, a White Paper entitled " Anti-Bribery Guidance for Transactions ." Although this version was preliminary draft, available for a commentary period and the ... Read More

If Only The Supreme Court Had Accepted Cert In The “Foreign Official” Challenge
Posted on 4 Mar 2015 by Mike Koehler

This article was reprinted with permission from FCPA Professor As highlighted here , here and here , last Fall the Supreme Court had the opportunity to correct the 11th Circuit’s flawed interpretation of the important “foreign official”... Read More