Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
As Russia’s war of aggression against Ukraine continues to destroy lives, livelihoods, and infrastructure in the country, plans are being made for Ukraine’s recovery and reconstruction. It is likely to cost over a trillion dollars.… Continue Reading
The Inter-American Development Bank (IDB) debarred a Brazilian construction company Tuesday for a year and a half for corrupt and fraudulent practices related to a project in Brazil.… Continue Reading
The Law Commission published the long-awaited Corporate Liability Options Paper on June 10, 2022. This followed a request by the British Government in November 2022 to consider “the challenges faced by the criminal justice system under the current law relating to corporate criminal liability .”… Continue Reading
This post is about internet censorship. That, ironically, is a prohibited topic under China’s rapidly expanding censorship regime. Because I’ll talk about SEC registrants who warn investors about China’s internet censorship as a risk factor, that’ll likely add to the illegality.… Continue Reading
A major inquiry has revealed what I and many others in the fraud space have long said: money laundering is rampant in one of Canada’s main provinces, British Columbia (B.C.), and the few cursory efforts made by the federal and provincial governments to tackle it have been largely ineffective. … Continue Reading
In 2018, the UK Serious Fraud Office recovered £4.4 million ($6.2 million) from two Chad diplomats who took bribes from Canadian oil company Griffiths Energy in the U.S and Canada. The recovered money was transferred to Chad and used in aid and development programs.… Continue Reading
So far in 2022, there have been four FCPA enforcement actions totaling $865 million in penalties and disgorgement. That pushes all-time FCPA resolutions over $24 billion.… Continue Reading
Glencore’s FCPA resolution last month included a plea agreement requiring the parent company’s Chief Compliance Officer to certify its compliance program and reports to the DOJ. The CCO’s certification is subject to the false statements statute, punishable by up to five years in prison, and the federal obstruction law, which carries a potential prison sentence of up to 20 years.… Continue Reading
Compliance requires lots of mid-course corrections. Those corrections are based on constant feedback that’s honest and accurate. That’s why attempts to impede feedback and complaints are always bad for compliance. And yet, confidentiality agreements (in their many different forms) are everywhere.… Continue Reading
The Texas-based oil and gas giant employs over 65,000 people and has refineries in 21 countries. At 18 pages, ExxonMobil’s anti-bribery policy is the second longest we’ve seen behind VW’s 36-page policy.… Continue Reading
In the past couple of months, sanction list screening has become one of the most critical compliance tasks. A single question has triggered much of the change: “Are my business partners and other third parties I deal with really sanctioned?”… Continue Reading
The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading
