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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

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

New Proposal For FCPA ‘Adequate Procedures’ Defense

Jon Jordan, a friend of the FCPA Blog, has just published a new article in the Stanford Journal of Law, Business & Finance.

It discusses the adequate procedures defense under the UK Bribery Act and explores suggestions for a similar kind of compliance procedures defense under the FCPA.… Continue Reading

Sullivan, Sun, Secrecy — Get Us Out Of Here

Everywhere we live these days, governance problems — big, self-destructive, delusional, guaranteed-to-fail governance problems — are the talk of the town.

In Charlottesville, the University of Virginia just survived a ‘near death experience,’ as Rector Helen Dragas described it.… Continue Reading

Compliance Failures Helped China Develop Attack Helicopter

It’s not a bribery case. But it showed how the profit motive can overwhelm a compliance program.

A Canadian subsidiary of United Technologies pleaded guilty today to violating the Arms Export Control Act and making false statements in connection with illegal exports to China.… Continue Reading

Facilitating Payments (De)mystified (Conclusion)

In two prior posts we observed an awkward equivocation on the question of facilitation payments, both within the OECD generally and among the convention signatories. For a discussion of the OECD Convention’s strangely evasive verbiage, see here; for variations among individual signatories, see here.… Continue Reading

Will Total S.A. Fight Back?

In recent SEC filings, French oil giant Total said it rejected ‘out-of-court settlement solutions’ with the DOJ and SEC that would end their longstanding FCPA investigations. And while Total said it is still talking with the agencies, it also said it’s free not to settle, ‘in which case it would be exposed to the risk of prosecution in the United States.’… Continue Reading

SNC-Lavalin Execs Charged In Canada

Two executives from Montreal-based engineering firm SNC-Lavalin Group Inc were charged in a Toronto court Monday for bribing officials in Bangladesh.

Canada’s Corruption of Foreign Public Officials Act makes it an offense to directly or indirectly give or offer a loan, reward, advantage, or benefit of any kind to a foreign public official ‘in order to obtain or retain an advantage in the course of business.’… Continue Reading

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