The Foreign Corrupt Practices Act community is blessed with an active group of writers. Many of the writers approach the FCPA and related issues from different perspectives and with different goals in mind.
One of the most active writers on FCPA topics is Thomas Fox (FCPA Compliance and Ethics Blog). 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 digestable, 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 and 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.
As Fox says in conclusion:
“Anti-corruption compliance enforcement is here to stay. That means, in today’s business world, you will need to ensure effective anti-corruption compliance in almost any location where you do business, and at any entity you might choose to do business with going forward. An effective program should not be 100 paces past your company’s internal financial controls. It may be five paces beyond where you are now. It is not difficult to institute and follow such a standard, but it does take commitment from senior management to lead and support the effort going forward.”
If developing an FCPA compliance tool-kit is on your to-do list this year, you may want to add “Doing Compliance” to your bookshelf. The book can be ordered here and here.
