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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

A Word Of Thanks . . .

We’re always thankful for Fridays, of course, but today ranks above others. Finally we can say goodbye to October 2008 — a month that changed the world. We asked a friend for a favor last week.… Continue Reading

Limiting The Local Law Defense

The Opinion and Order in U.S. v. Kozeny issued October 21, 2008 mentioned in our post yesterday deals directly with the Foreign Corrupt Practices Act’s local law affirmative defense. That defense says a bribe paid to a foreign official is permitted if it was “lawful under the written laws and regulations of the foreign official’s” country.… Continue Reading

In Bourke’s Case, We Stand Corrected

We never forget how many of our readers are real experts in the Foreign Corrupt Practices Act. And how generous they are with their help. It happened again late last week when they asked us to set the record straight in U.S.Continue Reading

Use It Or Lose It

We always enjoy it when Pete from DC drops by the blog. He’s a veteran compliance professional and thinks deep thoughts about the Foreign Corrupt Practices Act. Lately, he told us, he’s been thinking about audit rights — the kind mentioned in our recent post about joint ventures.Continue Reading

Business Down, Compliance Risks Up

When times are tough and markets shrink, new international joint ventures sprout up everywhere. They’re a fast and inexpensive way to expand commercial reach. JVs formed out of economic necessity often bring together companies that in good times are competitors.… Continue Reading

Looking Through The FCPA

Legal loopholes, the conventional wisdom goes, expand over time, until there’s more hole than donut. But is that true of the Foreign Corrupt Practices Act? Have its three Congressionally created loopholes — two affirmative defenses and one exception — gotten bigger over time?… Continue Reading

Surveying FCPA Compliance

Eighty percent of U.S. companies have now banned facilitating payments entirely, and nearly four in ten small U.S. companies have walked away from business in countries where the perceived risk of non-compliance was too high.… Continue Reading

Comments To What’s The Count

Nine out of 10 visitors to this blog (according to view our posts through a reader such as Google Feedfetcher or an aggregator. That means most visitors normally don’t see comments (or the buttons and other information to the right).… Continue Reading

What’s The Count?

Some weekend. We should’ve expected it since the calendar says mid-October. That always means one thing, or maybe two. The sky is falling on Wall Street . . . and the American League Championship Series is in full swing, literally.… Continue Reading