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

For compliance databases, a ‘no hit’ isn’t a green light

The recent Cobham Holdings Inc. OFAC settlement highlights a limitation in due diligence software: Cobham’s screening partner ran a name through a database and received no hits.

The name was later found to be a variation of a hit from the OFAC sanctions list, but wasn’t picked up due to the limitations of the search parameters. 

While companies who find themselves in this situation look to and hold their screening partner responsible, database and continuous monitoring services should be considered a minimum tool available for a compliance program’s due diligence.Continue Reading

Five years ago, I was walking out of prison

Whenever I hear about an FCPA sentencing that involves time in federal prison, I think of the day in July 2012 when I faced the judge and learned my fate.

I recall so clearly the anxiety of standing before Judge Richard Leon in DC, knowing that before I left the courtroom a sentence would be pronounced which would have life changing consequences. 

When Judge Leon sentenced me to eighteen months in federal prison, I felt anxiety at my custodial sentence instead of home confinement, as the government recommended.… Continue Reading