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
America’s first blogger, Ben Franklin, wrote in his 1791 autobiography that if you want someone to like you more, ask them for a favor.… Continue Reading
Have you noticed how many corporate FCPA enforcement actions recount old facts. Really old facts — sometimes from more than a decade ago. Why should we care about all that ancient history?… Continue Reading
As Salomé Lemasson’s excellent post earlier this week reported, a new level of corporate accountability for overseas bribery and ESG is breaking out across Europe. That’s welcome news, especially to those of us who once wondered if corporations there would ever face the music.… Continue Reading
We know a lot about what the feds expect from compliance training. For example, from the Evaluation of Corporate Compliance Programs and the FCPA Resource Guide, we know training is a hallmark of a well-designed compliance program. … Continue Reading
The SEC guards the integrity of U.S. markets and protects investors by requiring issuers to disclose material information about themselves and their directors and officers. However, the SEC doesn’t tell anyone what to say or how to say it.… Continue Reading
The DOJ and SEC have prosecuted 240 different companies (by my count) for FCPA offenses. Of those 240 companies, 13 have been repeat FCPA defendants. That means the recidivism rate for all corporate FCPA defendants is about 5.5 percent.… Continue Reading
It was my job to tell the bright young employee he was being fired. I was the company’s outside counsel in Southeast Asia and the employee, a Singaporean, worked mainly in Malaysia.… Continue Reading
In nearly all FCPA enforcement actions, agents, consultants, suppliers, distributors, and partners — whether real or faux — have a hand in bribery. They make approaches to foreign officials, set up offshore shell companies, generate fake invoices, and move money through accounts they own or control.… Continue Reading
A root cause of the spectacular failure of nearly 20 years of nation-building in Afghanistan is endemic corruption.… Continue Reading
The United States reported its first coronavirus death on February 29, 2020. Two weeks later, on March 15, the CDC advised against gatherings of more than 50 people. That started the chain of events that led to widespread lockdowns and nearly universal work-from-home.… Continue Reading
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
