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
In 2007, we listed ten elements of an effective compliance program. Several elements made it clear that high-level oversight is always critical. In IBM’s case, that oversight was missing.
On Friday, the company paid $10 million to settle civil FCPA charges brought by the SEC for violations in Korea and China.… Continue Reading
