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Harry Cassin
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Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
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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
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Shruti J. Shah
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Russell A. Stamets
Contributing Editor

Richard Bistrong
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Eric Carlson
Contributing Editor

Solving The Problem of Gifts, Meals, and Entertainment Expenses

Last week on Corruption, Crime & Compllance, I wrote that the increase in FCPA enforcement has led to ‘mass hysteria,’ whipped up by lawyers and others.

But there’s a shortage of practical solutions, especially when it comes to gifts, meals and entertainment expenses.

In my post, I suggested an approach that is less technical and more common-sense based. ‘Negligent conduct,’ I said, ‘does not mean criminal conduct. Mistakes are not criminal.’

I hope readers of the FCPA Blog will find the post useful.

It can be found here.

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Michael Volkov is the primary contributor to Corruption, Crime & Compliance. He’s a former federal prosecutor and now a partner at Mayer Brown LLP in Washington, D.C. He regularly counsels and represents clients on FCPA and UK Anti-Bribery Act issues. He can be contacted here.

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