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
Know-your-customer is usually associated with anti-money laundering programs. Customers (or clients) with close ties to corrupt leaders, for example, are flagged as an AML risk. But KYC also applies to FCPA risk analysis, but in a very different way.… Continue Reading
Compliance training doesn’t always work. Sometimes trainers and trainees don’t click. Sessions are flat. Trainees are unengaged, bored, and sleepy. What’s gone wrong?… Continue Reading
They are so familiar to those of us who follow FCPA enforcement actions that we’re likely to stop noticing them. Petrobras in Brazil, Corpoelec and PDVSA in Venezuela, Pemex and CFE in Mexico, Takilant in Uzbekistan, Sonangol in Angola, Alba in Bahrain, Telecommunications D’Haiti, 1MDB in Malaysia, and Pertamina in Indonesia.… Continue Reading
They craft policies, train employees, oversee due diligence, perform risk assessments, and lead investigations. But there’s another compliance role that’s practically unknown: disciplinarian. … Continue Reading
It’s a strange scenario. How did London-based Amec Foster Wheeler (AFW) end up with agents in three different countries for a single, relatively small project in Brazil — including two agents disqualified by AFW’s due diligence and a third agent that AFW thought had lost influence?… Continue Reading
Every compliance training session should include this warning: If you ever become involved with, see, or otherwise discover a potential FCPA violation, stop everything. Don’t clean your desk, empty the trash can, or clear your browser history.… Continue Reading
Nothing sells itself, not even compliance. There’s always a process of presentation. So if we talk about “marketing” compliance, we’re not cheapening it. Instead, we’re trying to understand how compliance officers can be most effective.… Continue Reading
Why is cooperation in corporate enforcement actions such a big deal? Because from the outside, most companies are a black box. Without help, it’s impossible to know what happens inside.… Continue Reading
The first four months of 2021 saw only one FCPA enforcement action against a corporate defendant. That’s the slowest start for at least 10 years.… Continue Reading
It occurred to me that work-from-home has always been the norm for writers. So I wondered how seasoned professionals handle all the WFH temptations to procrastinate. Are there lessons for the rest of us?… Continue Reading
In an SEC filing Tuesday, Zurich-based Credit Suisse Group SA said it wrote down $4.7 billion in bad loans, and chief risk and compliance officer Lara Warner was “stepping down” from her role on the executive board effective that day and leaving the bank.… Continue Reading
You may have noticed a risk factor in annual reports and SEC registration statements about “conflicting laws and regulations.” Once rare, the warning has become common, thanks to globalized operations and proliferating regulators.… Continue Reading
