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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

Dun & Bradstreet pays $9 million to resolve China FCPA offenses

Dun & Bradstreet Corporation agreed Monday to pay more than $9 million to resolve Foreign Corrupt Practices Act charges arising from improper payments made by two Chinese subsidiaries.

The subsidiaries “used third-party agents to make unlawful payments to obtain data vital to Dun & Bradstreet’s business as a provider of business financial information,” the SEC said.… Continue Reading

Tom Fox: Where are England’s whistleblowers?

The case of Barclays chief Jes Staley attempting to unmask an anonymous whistleblower came to an almost imperceptible and silent ending recently when the UK’s Financial Conduct Authority concluded that Staley’s actions were not done intentionally but apparently with some other, lesser standard.… Continue Reading

Wendt and Sultan on oral downloads: What should counsel share with the SEC?

In prior posts, we covered (1) how two former General Cable executives, now defendants in an SEC enforcement action, sought to compel Morgan Lewis (General Cable’s counsel) to share interview memoranda and notes, investigation reports and other materials from the firm’s internal investigation, and (2) how Judge Jonathan Goodman ruled in the defendants’ favor in part by holding that Morgan Lewis had waived work product protections through oral disclosures of interviews to the SEC.… Continue Reading

Resource Alert: Mastercard training video now available to everyone

Companies often ask me to record video for internal training. They want real-world stories of corruption and commerce which they can embed into existing on-line anti-bribery compliance training.

Mastercard took that to a new level when they engaged a production company to depict chapters of my own FCPA violations, eventual guilty plea, and my sentencing to fourteen and a half months in prison.… Continue Reading

Job: Director, Ethics & Compliance Officer

Job Title: Director, Ethics & Compliance Officer

Employer: Boehringer Ingelheim

Location: Duluth, Georgia USA

Description: As a member of the U.S. Ethics & Compliance Leadership Team, the Local Ethics and Compliance Officer (“E&CO”) will provide E&C expertise to Boehringer Ingelheim USA (“BI-USA”) with a primary focus on BI U.S.… Continue Reading