Skip to content

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

All posts by Richard L. Cassin

Is corruption a root cause of trade secret thefts?

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

Board-level ‘risk committees’ are great, unless they destroy the company

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

Is the biggest global risk factor hiding in plain sight?

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

Root Cause Analysis: Does ‘5 Whys’ work for compliance?

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

What’s the collateral damage from Ericsson’s DPA breach?

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