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
One of the byproducts of our locked-down, socially distanced, mask-wearing, remote-working world is that introverts are feeling more comfortable. They don’t need to pretend to be part of the gregarious, fist-bumping, loud-talking in-crowd of corporate extroverts, and that’s a big relief.… Continue Reading
It’s a familiar FCPA enforcement pattern. Companies in the same segment fall like dominoes. Medical device makers, pharmas, banks, mobile phone operators, oil and gas service providers and producers — all have had their turn in the enforcement spotlight.… Continue Reading
A few days ago, before the mob had stormed and ransacked the U.S. Capitol, when our only disruptive crisis was a deadly pandemic, I told my publisher and editor that January 2021 already seems as bad as December 2020.… Continue Reading
Beginning in 2008, when Siemens resolved its mega-FCPA case for $800 million, December has been a month of FCPA fireworks.… Continue Reading
Due diligence turns up a lot of ugly stuff. Sometimes compliance professionals learn too much. In those cases, what should they do? When does a bad fact or tainted deal become a police matter?… Continue Reading
For the FCPA community (and the entire human race), 2020 was a You’ve-Got-to-be-Kidding-Me year. But for our top stories, let’s jump past the pandemic and straight to the FCPA, and more specifically to three aspects of enforcement — the Good, the Bad, and the Missing.… Continue Reading
When the SEC launched its whistleblower reward program in 2011, many predicted a flood of FCPA complaints. That didn’t happen. From FY2012 through FY2020, the SEC logged over 40,000 tips overall, but just 1,667 FCPA tips, or an average of 185 a year.… Continue Reading
At work, when a boss or colleague insults us, whether intentionally or not, we feel it. Our usual reaction? Clam up and retreat into our shell.… Continue Reading
Last month, on the same day the DOJ and SEC imposed $3.3 billion in financial penalties against Goldman Sachs for 1MDB-related FCPA violations, Goldman’s board announced a plan to claw back $174 million from former and current executives.… Continue Reading
How much due diligence is enough when dealing with Chinese companies? Here’s a better way to ask the question: If Chinese companies are beyond the reach of U.S. law, is any amount of due diligence enough?… Continue Reading
As part of Goldman Sachs’ record-breaking $3.3 billion FCPA resolution, the SEC ordered the company to disgorge $606.3 million. That’s the second biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
How to explain it? Beam Suntory’s 2018 FCPA civil settlement with the SEC went so well. The SEC praised the company’s cooperation and took into account its good behavior. And yet in 2020, when Beam Suntory finally resolved criminal FCPA charges, the DOJ brought faint praise and heavy criticism, citing the company’s “inconsistent and, at times, inadequate cooperation,” among other transgressions.… Continue Reading
