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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

2020 has been a crazy year for the FCPA too

While we have understandably been distracted by the challenges of 2020 – from serious concerns about our health and the well-being of our loved ones to not-so-serious concerns of how we look on video conferences – things in the FCPA world have been humming along.… Continue Reading

The SEC is on an ‘internal controls rampage’ when it comes to third-party relationships

Over the last two years, the Securities and Exchange Commission has set its sights on distributor and reseller relationships, and excoriated companies that failed to adequately manage and supervise them. The focus on these third-party relationships is part of the agency’s broader application of the FCPA’s internal controls provision in an increasingly aggressive manner.… Continue Reading

Practice Alert: Is every email another FCPA violation?

Last month, while all eyes in the FCPA world were on the acquittal of former Alstom executive Lawrence Hoskins in the U.S. District Court for the District of Connecticut, a far more significant FCPA decision was delivered a bit further down the coast by Judge Kevin McNulty of New Jersey’s federal trial court.… Continue Reading

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