Job: Associate General Counsel, Ethics and Compliance
The FCPA Blog
March 29, 2021
Job Title: Associate General Counsel, Ethics and Compliance 
Employer: Bloom Energy
Location: San Jose, California USA… Continue Reading
Editors
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
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
Should compliance departments be forced to compete with outside providers?
Richard L. Cassin
March 25, 2021
We all know this about corporate life: Support functions are the exclusive responsibility of designated groups. If you need or want compliance help, for example, you have to ask the compliance department.… Continue Reading
Benchmarking Alert: Here’s the full Microsoft anti-corruption policy
Harry Cassin
March 24, 2021
Microsoft has one of the most interesting anti-corruption policies we’ve reviewed and the only one to cover two rarely acknowledged topics: extortion and threats. … Continue Reading
In France, bribery isn’t needed to violate the anti-bribery law
Andy Spalding
March 23, 2021
The French Anti-Corruption Agency (AFA) has just published the English version of its revised anti-corruption compliance Guidelines. Reflecting three years of experience in implementing France’s landmark Sapin II law, the Guidelines lay out the agency’s recommendations for both the public and private sectors.… Continue Reading
It’s been a quiet Q1 for FCPA enforcement. Is that good or bad?
Harry Cassin
March 22, 2021
So far in 2021, not much has happened in the world of FCPA enforcement. No big fireworks. No splashy headlines. Is that good or bad?… Continue Reading
Toyota discloses ‘possible anti-bribery violations’
Harry Cassin
March 18, 2021
Japan’s Toyota Motor Corporation said in an SEC filing Thursday that it reported “possible anti-bribery violations” to the DOJ and SEC.… Continue Reading
Compliance Training: Five reasons why you have an anti-corruption program
Richard L. Cassin
March 18, 2021
Here’s a strange fact. Some corporate anti-bribery policies give no reason for employees not to pay bribes. Or rather, the only reason they give is that the company doesn’t allow or tolerate bribery.… Continue Reading
Benchmarking Alert: Here’s the full Novartis anti-bribery policy
Harry Cassin
March 17, 2021
Novartis updated its anti-bribery policy four months after the Swiss pharma paid $346.7 million to resolve FCPA offenses in Greece, Vietnam, and South Korea. Here are some interesting details from the latest version.… Continue Reading
Chemical giant Braskem discloses new corruption investigation
Harry Cassin
March 15, 2021
Brazilian petrochemical maker Braskem S.A. disclosed in an SEC filing late Friday that it is investigating alleged “improper payments” related to an ethylene project in Mexico.… Continue Reading
Is compliance a young person’s profession?
Richard L. Cassin
March 11, 2021
Although we all celebrate birthdays and keep close track of our age, you can’t do that in the workplace anymore. So there’s no reliable information out there about the average age of compliance officers.… Continue Reading
Benchmarking Alert: Here’s Tesla’s full anti-corruption policy
Harry Cassin
March 10, 2021
Elon Musk is well known for his brevity on Twitter, and Tesla’s worldwide bribery and anti-corruption policy shows the compliance department also likes to keep things simple. … Continue Reading
In Kosovo, an anti-corruption agenda for a self-determined movement
Vlora Marmullakaj
March 9, 2021
On February 14, citizens of Kosovo cast their vote for parliamentary elections. That day, Kosovo witnessed deep democratization where a grass-root movement named Vetevendosje (“self-determination” in English) won the elections with the highest percentage any one party has ever reached since the war in 1999.… Continue Reading