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Editors

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Harry Cassin
Publisher and Editor

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Andy Spalding
Senior Editor

Jessica Tillipman FCPA Blog

Jessica Tillipman
Senior Editor

WILLIAM B.F. STEINMAN

Bill Steinman
Senior Editor

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Richard L. Cassin
Editor at Large

Elizabeth K. Spahn

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington

Cody Worthington
Contributing Editor

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Julie DiMauro
Contributing Editor

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Thomas Fox
Contributing Editor

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Marc Alain Bohn
Contributing Editor

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Bill Waite
Contributing Editor

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Shruti J. Shah
Contributing Editor

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Russell A. Stamets
Contributing Editor

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Richard Bistrong
Contributing Editor

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Eric Carlson
Contributing Editor

Job: General Counsel, Government Services

The FCPA Blog July 11, 2019

Job Title: General Counsel, Government Services

Employer: Day & Zimmermann

Location: Chantilly, Virginia USA

Description: The General Counsel is the chief legal officer for Day & Zimmermann’s Government Services Business Unit (DZGS), a leading government services contractor providing mission-critical safeguards and security; facility management and operations; architecture and engineering services; explosive ordnance storage and disposal; international logistics; and life support services.… Continue Reading

The new star of the DOJ Guidance is ‘risk’

Worth MacMurray and Dennis Chesley July 11, 2019

The DOJ’s April 2019 guidance for prosecutors on compliance programs reflects a belief that even as risk taking drives business behavior, so too should legal (particularly criminal) risk drive and inform a business’s compliance program.… Continue Reading

FCPA defendants need an ‘adequate procedures’ defense, too

Jesse Van Genugten July 10, 2019

The Department of Justice recently updated and published its guidelines for evaluating corporate compliance programs in the FCPA context. The Guidelines are remarkably thorough, but the text is aimed principally at assisting prosecutors with charging decisions, setting sanction amounts, and crafting subsequent compliance obligations — rather than at the corporate entities that are expected to phase in those compliance programs.… Continue Reading

D&O Liability Insurance: Hazards for the CCO

Janaya Moscony and Julie DiMauro July 10, 2019

Legal claims are regularly brought against corporate officials through a wide variety of angles, including, for example, allegations of breach of fiduciary duty and willful disregard of regulatory imperatives, or for a range of statutory violations premised in financial crimes, like bribery or insider trading.… Continue Reading

Here’s my advice, from the heart, to any FCPA defendant

Richard Bistrong July 9, 2019

Not all FBI stings in FCPA cases are alike. That became clear in the prosecution of Roger Richard Boncy and Joseph Baptiste. They were found guilty of FCPA and related offenses last month after a two-week jury trial in which the DOJ said they solicited “bribes from undercover agents posing as potential investors in a proposed port development project in the Mȏle St.… Continue Reading

Job: Investigations Manager (Prevention & Response)

The FCPA Blog July 3, 2019

Job Title: Investigations Manager (Prevention & Response)

Employer: Tearfund

Location: Teddington, United Kingdom

Description: We are committed to the highest standards of integrity, and to avoiding harm in our work. As part of this, we have created the role of Investigations Manager to enhance our effectiveness in preventing and responding to wrongdoing.… Continue Reading

The AI due diligence revolution has begun

Aaron Narva and Victoria Sztanek July 3, 2019

As the ecosystem of third parties continues to grow, AML due diligence has become more difficult. The challenge of identifying and vetting suppliers, consultants, agents, affiliates and resellers would be insurmountable without the use of technology.… Continue Reading