I am extraordinarily pleased to announce that Compliance Week has released my most recent hardbound book, Doing Compliance: How to Design, Create, and Implement an Effective Anti-Corruption Compliance Program, in both Amazon Kindle and Apple iBook formats. Of course you can also purchase a hard copy to keep on your reference shelf as well. It is the book that a compliance practitioner should use as a one-volume reference for the everyday ‘Nuts and Bolts’ work of anti-corruption compliance.
Just as the world becomes more flat for business and commercial operations, it is also becoming so for anti-corruption and anti-bribery enforcement. Any company that does business internationally must be ready to deal with a business environment with these new realities. Doing Compliance is designed to be a one-volume work that will give to you some of the basics of creating and maintaining an anti-corruption and anti-bribery compliance program that will meet any business climate you face across the globe. The book format is an easy reference to assist you with your compliance program and I have based my discussion of a best practices compliance program on what the Criminal Division of the US Department of Justice (DOJ) and Enforcement Division of the Securities and Exchange Commission (SEC) set out in their jointly produced “A Resource Guide to the U.S. Foreign Corrupt Practices Act” (the FCPA Guidance) and the “Ten Hallmarks of an Effective Compliance Program”.
The FCPA Guidance wisely made clear that there is no ‘one-size-fits-all’ approach when it stated, “Individual companies may have different compliance needs depending on their size and the particular risks associated with their businesses, among other factors.” Thus, the book is written to provide insight into the aspects of compliance programs that the DOJ and SEC assess, recognizing that companies may consider a variety of factors when making their own determination of what is appropriate for their specific business needs.
The book has struck a cord with other well-known figures in the compliance community. Professor Andy Spalding, writing in the FCPA Blog, in a post entitled “Book Review: Tom Fox’s Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program”, said, “Compliance must be thorough, systematic, and highly attentive to detail. But no one ever said it had to be boring. And Tom Fox has proven this yet again. His Doing Compliance provides the most sophisticated and comprehensive compliance guidance available, with a delivery that is witty, lively, and even entertaining.”
The FCPA Professor, in a post entitled “Doing Compliance” – An FCPA Compliance Toolbox”, said, “Fox approaches the FCPA and related topics with a singular goal in mind: analyzing and articulating the vast body of literature on FCPA best practices in a digestible, practical, and workable way to be of value to compliance professionals in the field. In short, Fox is the “nuts and bolts” guy of FCPA compliance who not only offers his own insight and perspective on best practices, but also effectively aggregates the insights and perspectives of others. Fox’s latest book is “Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program” and in it he provides, in his words, “the basics of how to create and maintain an anti-corruption and anti-bribery compliance program to suit any business climate across the globe.” The nine chapters of the book are grouped around topics such as senior management commitment to compliance; written policies and procedures; conducting a risk assessment; training; hiring and other human resources issues; reporting and investigation; and merger and acquisition due diligence. “Doing Compliance” is peppered with many helpful checklists and factors that compliance professionals can use on a daily basis to implement, assess and improve FCPA compliance policies and procedures.”
This book does not discuss the underlying basis of the FCPA, the UK Bribery Act or any other anti-corruption or anti-bribery legislation. The book is about doing business in compliance with these laws. As with all Americans, I appreciate any list that is deca-based, so the format of 10 hallmarks resonates with me. I have used this basic ten-part organization in laying out what I think you should consider in your anti-corruption and anti-bribery compliance program. In addition to presenting my own views in these areas, I also set out the views of both FCPA practitioners and commentators from other areas of business study and review, including Mike Volkov, the FCPA Professor, David Lawler, Stephen Martin, Marjorie Doyle, Russ Berland and Scott Moritz, and many others.
If there is one book on the ‘Nuts and Bolts’ of how to design, create and implement a best practices compliance program, I submit to you this is the one. I hope that you will check it out in one of the new formats now available. Finally, the price is set at a very reasonable $69.95 so if you are a Chief Compliance Officer (CCO) or General Counsel (GC), you can purchase an entire set for your compliance team. You can even buy them for your friends and family if you want them to have a better understanding of what you do at work!
To purchase a copy of Doing Compliance: How to Design, Create, and Implement an Effective Anti-Corruption Compliance Program click on one of the links below:
This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at firstname.lastname@example.org.
© Thomas R. Fox, 2015