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WHITEPAPER | Effective FCPA Compliance During Economic Downturns

How Compliance Should Prepare for and Respond to Economic Downturns

Compliance is often mistakenly viewed as a non-revenue generating unit of a business, which explains why many companies cut their compliance function during economic downturns. Yet these cuts are often a short-term cost-saving measure that brings expensive long-term consequences. Compliance officers need to be prepared for responding to economic downturns because the resulting price and market fluctuations bring with them numerous compliance risks.

As Tom Fox, noted FCPA expert, points out, the SEC and DOJ do not look kindly upon companies that decrease their compliance budget just because their income decreases. In fact, effective FCPA compliance would call for the opposite.

You will learn:

  • The mistakes companies commonly make during recessions
  • How to demonstrate that compliance cuts directly correlate with increased compliance risks
  • How to reallocate resources from low- to high-risk areas
  • How to use a technological solution to manage your FCPA compliance program




Tom Fox, Principal
(Advanced Compliance Solutions)

Thomas Fox has practiced law in Houston for more than 30 years. He is now an Independent Consultant, assisting companies with anti-corruption, anti-bribery and FCPA compliance and international transaction issues. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. Previously he served as division counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division.

Tom is the author of the award winning and syndicated FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics.” His second book, “Best Practices Under the FCPA and Bribery Act” was released in April of 2013. He recently released his first eBook, “GSK In China: A Game Changer in Compliance.” He attended undergraduate school at the University of Texas, graduate school at Michigan State University and law school at the University of Michigan.

Awards & Certifications 2013 GRC 20/20 Technology Innovation Award 2013 TAG Top 40 Innovative Company 2012 IABC Gold Quill Award 2012 MarCom Award We self-certify compliance Safe Harbor Safe Harbor Certification SOC 2 Certification