Thomas Fox (JD Supra United Kingdom)

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running bribery and corruption scheme, approved at the highest levels of the organization and perpetrated in multiple countries.

American’s greatest living playwright died yesterday as Sam Shepard passed away from Lou Gehrig’s disease. According to his obituary in the New York Times (NYT) “In Mr. Shepard’s plays, the only undeniable truth is that of the mirage. From early pieces like “Chicago” (1965), written when Mr. Shepard was in his early 20s and staged in the margins of Off Off Broadway, to late works like “Heartless”

It has been known for some time that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have been investigating investment banks over their dealings with the Libyan sovereign wealth fund, known as the Libyan Investment Authority (LIA). In 2014 Wall Street Journal article, entitled “Probe Widens Into Dealings Between Finance Firms, Libya”, it said that US authorities were

Surf music is certainly an under-rated rock and roll genre. One of my favorites is The Trashmen’s Surfin’ Bird. It reached Number 4 on the Billboard Chart in 1963. I happened to hear it recently when I was reading about some interesting corporate governance issues and how they relate to anti-corruption compliance.

Readers of this blog know I am huge Civil War buff. Growing up in Texas, I only focused on the Southern side as a youngster and while this led to a sometime myopic view of events, in my mid-20s when I did begin to study the Northern side of the war, because I had never seriously studied from that perspective an entire panorama opened up for me.

April showers bring May flowers, at least that is the old truism. One place it is decidedly correct is at the RHS Chelsea Flower Show, which began its run as one of the, if not the greatest, annual flower shows in the world in May 1862.

Today we celebrate one of the great state of Texas’ greatest gifts to the musical world – the red headed stranger, Willie Nelson, who was born 29th April 1933.

It is an axiom in the trial lawyer world that bad facts make bad law. The reason is if the facts are particularly egregious, most judges and juries will go out of their way to try and see that justice is served if not done. An example might be from the arena of toxic torts where companies with de minimis involvement with asbestos and silicosis are dragged into multi-million dollar, seemingly...

We conclude our week of Sherlock Holmes inspired themes with one of the few cases in which Holmes fails to bring the criminals to justice, The Adventure of the Engineer’s Thumb. Once again using the Holmes tale as a contrast I refer to the recently released white paper, published by Transparency International UK (TI-UK), entitled “How to Bribe: A typology of Bribe-Paying and How to Stop It”

Last week, before O’Toole passed away, the UK Serious Fraud Office’s prosecution of Victor Dahdahleh also died when the SFO notified the Court that it did not believe a guilty verdict was possible due to some very odd in trial machinations. As you might expect, thebriberyact.com guys, Barry Vitou and Richard Kovalevsky QC, wrote about it in their blog, thebriberyact.com.

On this day 75 years ago Orson Welles caused a nationwide panic with his broadcast of “War of the Worlds” – a realistic radio dramatization of a Martian invasion of Earth. The show began on Sunday, October 30, at 8 pm.

Ed. Note-there have been some recent developments in the UK regarding the Bribery Act. TheBriberyAct.com guys, Barry Vitou and Richard Kovalevsky QC recently wrote about them.

Financial controls are rarely given top billing in an anti-corruption compliance program under the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. However, it turns out that financial controls are essential to the long term success of not only a compliance program but also to the great health and success of a company.

After the butt-slide play, you might think that the sad sack Houston Astros could not sink even lower but I guess setting the Major League Baseball (MLB) record for the worst record for three straight years is not enough. Yesterday, as reported by Sam Gardner in Fox Sports Online, in a post entitled “Buzz: Astros botch Ladies Night”, the Astros managed to insult over 50% of the population with...

A couple of weeks ago I had the opportunity to enjoy a day of fabulously sunny weather in London and, more importantly, have lunch with Barry Vitou, one of the two founding partners of the Blogsite, thebriberyact.com. So I am able to present the next installment of Lunch with the FCPA Compliance and Ethics Blog. Just as sometimes my inspiration, Lunch with the FT, travels to the US to interview a

From our deck chairs we thought we’d share this with you. An open letter from David Green, Director of the SFO, in connection with facilitation payments. Originally Published on thebriberyact.com - August 22, 2013.

Yesterday I used the lyrics from Emerson, Lake and Palmer’s song Karn Evil No. 9, First Impression, Pt. 2 - “Welcome Back My Friends, To The Show That Never Ends” as an entrée into the topic of the investigation of JP Morgan’s hiring practices in China and possible Foreign Corrupt Practices Act (FCPA) violations.

One of the critical areas in due diligence for foreign business partners is determining who are the true owners of an entity.

Today we celebrate that noted British comedian who made his fame in America – Bob Hope.

News reaches us of a private small round table session put together by Transparency International and attended by some from the US FCPA white collar community (we understand Mark Mendelsohn attended) and our very own David Green CB QC, Director of the Serious Fraud Office.

Ray Harryhausen died yesterday. For my money, he was the greatest special effects artist of the 20th century. I absolutely loved his stop motion animation.

Unlike that fabulous song-writing team of Lennon and McCartney, these two guys promised that they would be back and from what we have seen over the past few weeks, they have kept to their collective word. Yes, those two light-shiners on all things UK Bribery Act, thebriberyact.com guys have re-entered the blogging fray. While I will it to you to figure out which briberyact.com guy most closely...

In December 2012 the BBC online service reported that Rolls-Royce Motor Cars Limited (Rolls-Royce) was in talks with the UK Serious Fraud Office (SFO) regarding potential allegations of bribery and corruption in Indonesia and China.

I am a big fan of Sherlock Holmes, on radio, television and the movies but particularly in print. Last summer I re-read the Doyle collection and it was like revisiting and old friend. So today, we celebrate the story of the “The Six Napoleons”. In this story, an apparent thief is breaking into private residences and commercial establishments to seemingly smash statuettes of Napoleon....

Henry V is a truly inspiring play. Whether one sees it on the stage or on the big screen with the 1944 Olivier or 1989 Branagh version, one cannot help but draw inspiration about the story of the former Prince Hal, from Henry IV, who becomes a regal monarch and leads the English army to a defeat of the French at the Battle of Agincourt. One of the things that Henry V does extraordinarily well is...

As a father, I have come to appreciate Shakespeare’s Henry IV more and more; particularly more than I did when I was only a son. Part of the play deals with how Henry IV got his crown, by deposing Richard II and the battles he had to fight to keep it. But a large part of the play deals with his riotous son, Hal, drinking and philandering with Falstaff before he grew into the great monarch...

All of this brings me to the UK Bribery Act and the Six Principles of an Adequate Procedures compliance program and today’s topic, Principle II – Top-level Commitment. The purpose of Principle II is to encourage the involvement of top-level management in the determination of bribery prevention procedures. Under Principle II the top-level management of a business; whether a board of...

As The Clash sang, London Calling, and the London Olympics are now less than 100 days away. One of the areas which has generated the greatest amount of hyperbole is over corporate hospitality at the upcoming 2012 summer Games. There has been rampant speculation that under the UK Bribery Act, corporations may well be prosecuted for providing corporate hospitality events before or during the Games.