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

Many Companies’ Most Significant Regulatory Risks Are Not in Their Home Country
Posted on 23 Oct 2014 by Kevin M. LaCroix

When Chinese regulators hit GlaxoSmithKline with a $489 million penalty last month – the largest corporate penalty ever in China – it set off alarm bells around the world. Among other things it sent out a “wake-up call for global companies... Read More

One Anti-Corruption Compliance Panel: Multiple Perspectives
Posted on 29 Jul 2015 by RBistrong

On July 23 rd , 2015 at the Hotel Kitano in New York City, The Network ( ) hosted an Anti-Corruption Compliance Panel discussion titled “Why Anti-Bribery Programs Fail and How Compliance Must Evolve.” Cindy Curtin Knezevich... 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 Whole World Is Watching Mexico In the Fight Against Corruption
Posted on 22 Aug 2014 by Thomas Fox

Don Pardo died this week. While perhaps not of the public stature of Robin Williams or Lauren Bacall, whom we lost last week, his passing nonetheless was well noted in the national media. Pardo lived to the ripe old age of 96 and got his start in the... Read More

OCEG on Third Party Anti-Corruption Due Diligence
Posted on 10 Apr 2012 by Thomas Fox

My grandfather was a comic book collector. He collected all kinds and types of comics, from super-heroes to the Archie series. One of the series that he collected that I still think about from time-to-time was Classics Illustrated. Classics Illustrated... 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

The Five Essential Elements of a Corporate Compliance Program – Part II
Posted on 12 Sep 2012 by Thomas Fox

Yesterday, Stephen Martin and I co-presented at a Foreign Corrupt Practices Act (FCPA) event hosted by Kreller. If you are in or near Chicago, I hope that you can join us for this presentation. The title of our presentation is " Anti-Corruption/FCPA... 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

The United Nations Convention against Corruption: A New Focus?-Part I
Posted on 7 Sep 2011 by Thomas Fox

Ed. Note-today I begin a two-part series on the attempts to invoke the United Nations Convention against Corruption in the FCPA context. This article is written jointly with my colleague Mary Shaddock Jones. In an article published in the August... Read More

The Worst Conflict of Interest Move of All-Time (at Least Since Enron)
Posted on 13 Dec 2011 by Thomas Fox

Last week, I observed one of the worst actions by a major league sports commissioner in my lifetime. Not the worst, as I will give that "worst award for a decision made by a sports commissioner in my lifetime", to either of two Baseball Commissioners;... Read More

The United Nations Convention against Corruption: A New Focus?-Part II
Posted on 8 Sep 2011 by Thomas Fox

Ed. Note-Yesterday we began a two part series on the attempt by the NGO SERAP to invoke the United Nations Convention against Corruption on certain FCPA related matters. Today we conclude our series. This article is written jointly with my colleague... 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

The B20 Anti-Corruption Working Group Is Focused on the Right Topic, But It Is Unlikely That There Will Be Meaningful Action
Posted on 27 Aug 2014 by Mike Koehler

This article was reprinted with permission from FCPA Professor Earlier this summer, the B20 Anti-Corruption Working Group released this report detailing various policy recommendations to combating corruption. As highlighted on its website , the... Read More