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 family.
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 clicking here.
FCPA Compliance and Ethics Blog 