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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

Intermediaries: Separating red flags from red herrings

In this era of heightened FCPA enforcement, it is easy to assume that a red flag signals the end of a relationship with a business intermediary. By my count, 11 of the last 17 FCPA enforcement actions involved bribes funneled to foreign officials through third parties.… Continue Reading

Bill Steinman: An FCPA lawyer looks at Stars Wars

When Jimmy Carter signed the Foreign Corrupt Practices Act into law in December 1977, it couldn’t have been further from my mind. Had it entered my consciousness at all — which it likely didn’t — it would have been crowded out by Luke Skywalker, Chewbacca and Darth Vader.… Continue Reading

Bill Steinman: Remember the privilege and keep it sacred

Lawyers: As a group, we think we’re pretty special. Servants of the law and all that. But in truth, there’s really only one thing that sets us apart from other professionals: the attorney-client privilege (yes, yes, we can also represent others in court, but that’s not the point of this post). … Continue Reading

Bill Steinman on graft: Why we fight

My approach as a contributor to the FCPA Blog has been to take real world issues I encounter in my law practice and share practical approaches for overcoming them. Today’s post will be different. … Continue Reading

Bill Steinman: Can you trust your offset advisor?

Satisfying offset obligations is hard. Readers will recall that offsets are financial obligations imposed on defense contractors by foreign government customers as a condition to defense procurements.  

For every dollar of financial benefit the defense contractor creates in the country in question, it is given credit towards satisfying its obligation. Continue Reading