Over the past few years I have tried to provide the compliance practitioner with solid information that can be used to implement, review and enhance a US Foreign Corrupt Practices Act (FCPA) or UK Bribery Act based compliance program. I am often asked to collect my blog posting regarding what are the current best practices for an anti-corruption/anti-bribery compliance program. In other words, what are the specifics of a compliance program? This volume is an attempt to provide the compliance practitioner with information that can be used for the ‘nuts and bolts’ of compliance. Using a format similar to the recent US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) guide, “A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Foreign Corrupt Practices Act (FCPA)” [the “Guidance”], I have included some of my thoughts on what you can do to create and maintain a best practices compliance program. I have also included some of my prior articles on how to create and maintain such a compliance program using the Six Principles of Adequate Procedures compliance regime under the UK Bribery Act.
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Thomas Fox has practiced law in Houston for 30 years. He is now an Independent Consultant, assisting companies with FCPA and compliance issues. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was involved with compliance investigations, audits, drafted policies and led training on all facets of compliance including FCPA, export, anti-boycott and commercial operations training. He was previously division counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its largest division, then named Drilling Formation and Evaluation Division, worldwide. Tom has the award winning Blogsite, FCPA Compliance and Ethics Blog and has recently released his first book, Lessons Learned on Compliance and Ethics. He writes and lectures nationally and internationally on anti-corruption and anti-bribery compliance programs. Tom attended undergraduate school at the University of Texas, Graduate School at Michigan State University and law school at the University of Michigan.
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