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
First came the stunning news from the SEC on May 5th: it awarded a record $279 million to a whistleblower, dwarfing the previous record of $114 million set in 2020. Then last week the Wall Street Journal reported that the award was related to Ericsson’s $1.1 billion FCPA settlement with the DOJ and SEC in 2019.… Continue Reading
Memorial Day is complicated. We honor not war but those who do not return from war.… Continue Reading
Even by today’s larcenous standards, last week’s indictment of a former Apple software engineer for theft of trade secrets is shocking. The DOJ accuses Weibo Wang of stealing the heart and soul of Apple’s self-driving car technology, including the architecture for an autonomous system and the “entire autonomy source code.”… Continue Reading
An alarming aspect of the March meltdown that took out Silicon Valley Bank (SVB), Signature Bank, and First Republic Bank is that each had a stand-alone risk committee. We need to know what went wrong because risk committees are now commonly found at “most large companies,” according to a Big Four audit partner I talked to, and are assumed to protect against imprudent governance and management.… Continue Reading
Last week I wrote about three global trends creating risk and exerting a powerful influence on compliance — population growth, swelling money supply, and proliferating regulation. There’s another global trend but it’s usually overlooked in conversations about risk and compliance: urbanization.… Continue Reading
Whenever I’ve talked to groups about compliance — particularly younger people from universities, banks, and big companies — someone asks, “Does the compliance profession have a promising future?” My answer is always yes.… Continue Reading
It’s hard to think of JPMorgan Chase Bank — a behemoth with more than $3 trillion in total assets, market cap of $415 billion, the fifth biggest bank in world — as a hapless victim deserving our sympathy.… Continue Reading
Corporate FCPA defendants hoping for declinations must demonstrate that they’ve performed a root cause analysis and remediated the underlying conduct. The DOJ doesn’t tell companies how to do the root cause analysis, and there are many methods to pick from — Scatter Plot Diagram, Fishbone Diagram, Failure Mode and Effects Analysis (FMEA), and Pareto Chart, among others.… Continue Reading
How do public company audit committees cope? Their to-do list keeps getting longer and more complicated. Yet somehow, most audit committees still complete their tasks (which, by the way, include FCPA compliance oversight).… Continue Reading
Miranda warnings or their absence are rarely a factor in FCPA cases. Most individuals accused of FCPA violations take plea deals, and what happens procedurally before the plea probably doesn’t matter later.… Continue Reading
Earlier this month, telecom giant Ericsson agreed to resolve breaches of its 2019 FCPA DPA by paying $206.7 million in new penalties and pleading guilty to charges deferred by the DPA — one count of conspiracy to violate the FCPA anti-bribery provisions and one count of conspiracy to violate the internal controls and books and records provisions.… Continue Reading
For three enterprising professors from Georgetown University, the early days of Covid-19 — before the vaccines, when none of us knew what to do outside our homes — created a pristine environment to study how people perceive and handle risk.… Continue Reading
