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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

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Is debarment for fraud ‘fair and appropriate’?

The use of debarment and other administrative sanctions as tools to fight corruption in international development projects is a topic that understandably raises many questions. Not the least of which, and one that the World Bank Group (WBG) Sanctions Board encounters often, is the question of proportionality.Continue Reading

Switzerland now has mandated human rights due diligence

In our previous post, we highlighted that Switzerland was going to reform its Code of Obligations (CO) and Criminal Code concerning transparency on non-financial matters as well as due diligence and transparency duties with respect to minerals and metals from conflict zones and child labor.Continue Reading

Behavioral ethics and ‘middle-aged’ compliance programs

Last November marked the thirtieth anniversary of the Federal Sentencing Guidelines for Organizations. Whether or not this officially constitutes middle age, it underscores that the government’s policy of promoting compliance & ethics (C&E ) programs is no longer “developmental,” which is how the Chair of the Sentencing Commission described it in those early days.Continue Reading

Should compliance officers accept incentive pay?

Performance bonuses are always an exciting upside. But what about compliance officers? Does incentive pay work for them? There are ways to measure performance and match it to rewards for most C-suiters, managers, and professional staff — sales targets, production goals, hiring matrixes, and so on.… Continue Reading

‘Fintech revolution’ shifts compliance landscape for banks

More and more, traditional banks are looking to acquire or partner with fintech firms. For the banks, it’s a way to expand their digital offerings across the financial services sector. And for the fintech firms — typically small, agile start-ups — it’s a way to get much needed capital.… Continue Reading

Is your boss a narcissist?

I’m not talking about bosses who are sometimes rude, occasionally thoughtless, and visibly ambitious. I’m talking about those bosses who have crossed the line into something a lot worse. Who — if they were ever to come under psychiatric scrutiny — would be diagnosed with narcissistic personality disorder.… Continue Reading