News and commentary about white-collar crime, enforcement, and compliance
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
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
So far this year, two FCPA enforcement actions have involved companies that resolved previous FCPA violations. With Tenaris in June, and Oracle this week, the number of FCPA recidivists rises to 15.… Continue Reading
American technology giant Oracle Corporation agreed Tuesday to pay the SEC $22.9 million to resolve charges that it violated the Foreign Corrupt Practices Act in Turkey, India, and the United Arab Emirates through subsidiaries that created and used slush funds to bribe foreign officials in return for business.… Continue Reading
Kraft Heinz produces some of the world’s favorite foods that have been pantry staples for generations. Every person reading this post is almost certain to have at least one Kraft Heinz product in their kitchen.… Continue Reading
The early identification of fraud risks or vulnerabilities in projects is a major concern of investors and international financial institutions. The European Investment Bank (EIB) undertakes Proactive Integrity Reviews (PIRs) to identify such potential vulnerabilities and major fraud risks in EIB-funded operations and projects.… Continue Reading
When the DOJ and SEC published their FCPA Resource Guide, they emphasized the connection between remedial action and enforcement. The Guide makes clear that no company can expect a favorable FCPA resolution unless it takes adequate remedial action, and conversely, companies that fail to do that are more likely to face charges and harsher FCPA penalties.… Continue Reading
Deputy Attorney General Lisa Monaco’s speech and memo of September 15 and the DOJ Fraud Section’s hiring this month of Matthew Galvin, formerly the head of ethics and compliance at AB InBev, continues the steady surge of compliance resources and guidance provided by DOJ since 2019.… Continue Reading
We are continuing our exploration into behavioral science and its practical application to ethics and compliance. In previous posts, we’ve talked about behavioral risk hot spots, how to identify them and what’s the role of the underlying behavioral drivers.… Continue Reading
Brazil airline GOL Linhas Aéreas Inteligentes S.A. agreed to pay the DOJ and SEC $41.5 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to officials in Brazil to pass legislation benefitting the company.… Continue Reading
The world’s new standard for measuring and reporting ESG (environmental, social, and governance) is the Stakeholder Capitalism Metrics. That document was published in September 2020 under the auspices of the World Economic Forum “in collaboration with Deloitte, EY, KPMG and PwC.”… Continue Reading
An award-winning compliance training series expands this month as Mastercard and Front-Line Anti-Bribery LLC explore the potential perils of everyday activities. “Ordinary Situations, Extraordinary Risk” depicts actual events to help a company’s employees understand the impact of their decisions.… Continue Reading
The European Investment Bank and GE Steam Power have reached an agreement regarding historical cases of prohibited conduct by various Alstom Steam Power companies, in particular, Alstom Power Systems S.A (France), Alstom Power Systems GmbH (Germany), and Alstom Hrvatska d.o.o… Continue Reading
Contracts between companies and third parties might be the usual bailiwick of lawyers. But any robust program should give compliance officers a chance to know what compliance-related language is in those contracts, or what’s missing, and have a voice in the contract approval process.… Continue Reading