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
Our good fortune here at the FCPA Blog is to be able to think and talk about the Foreign Corrupt Practices Act. It’s not perfect — no human law is. But it makes a difference in the world by exposing and punishing public bribery.… Continue Reading
The Senate’s version of the financial reform bill can be downloaded here. Under the bill, which still needs to be reconciled with the House version and signed into law, FCPA whistleblowers could receive from 10% to 30% of amounts recovered through enforcement actions.… Continue Reading
A month ago we asked what’s wrong in Australia. Despite multiple overseas bribery scandals, there’s been no sign of enforcement activity by the Australian Securities & Investments Commission — the chief anti-corruption agency — or anyone else down under.… Continue Reading
By Jeffrey M. Kaplan and Rebecca Walker
As discussed in Part One of this post, the U.S. Sentencing Commission approved changes to the compliance-and-ethics (“C&E”) program-related provisions of the Federal Sentencing Guidelines for Organizations in April, one of which concerns steps companies should take after the discovery of criminal conduct.… Continue Reading
Last week we wondered why there hasn’t been a new FCPA enforcement action from the DOJ since Daimler’s on April 1. Among our guesses were personnel changes, trial-team stresses, and strategic reviews.… Continue Reading
We don’t normally follow snooker news (snooker is like billiards or pool but the balls have no numbers, just colors). And the U.K.’s News of the World isn’t one of our regular sources.… Continue Reading
There hasn’t been a new FCPA enforcement action from the DOJ since Daimler’s on April 1 and only Dimon’s from the SEC. That’s strange. The first three months of this year were the busiest in FCPA history.… Continue Reading
Iran has all the ingredients to be an FCPA minefield. It’s big — 66 million people in an area about the size of Alaska — and it’s the world’s 6th largest oil producer.… Continue Reading
By Jeffrey M. Kaplan and Rebecca Walker
In April, the U.S. Sentencing Commission approved changes to the compliance-and-ethics-program related provisions of the Federal Sentencing Guidelines for Organizations. Absent Congressional action to the contrary (which is quite unlikely), the changes will go into effect in early November.… Continue Reading
A story in the Financial Times (here) earlier this year said authorities in the U.S. and Ghana are investigating corruption allegations involving a privately held Texas oil company, Kosmos Energy.… Continue Reading
For the second time in recent months, U.K. judges have warned the Serious Fraud Office not to make plea deals in overseas bribery cases, throwing into doubt the agency’s whistleblower program and its partnership with the U.S.… Continue Reading
Dell Inc.’s FCPA compliance program was in the news this week for the right reasons. The program was certified by the Open Compliance & Ethics Group. The OCEG helps companies think about compliance systems that can be embedded into the corporate fabric.… Continue Reading
