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
An excellent post on the FCPA Blog last week from Matthew McFillin and Amanda Rigby of KPMG talked about Covid-19-caused government shutdowns, and delays companies are experiencing obtaining permits, licenses, visas, and the like.… Continue Reading
Until now, compliance officers have stayed mostly under the government radar. They aren’t regulated or licensed, tested or monitored. Will that change? And if so, what might the next stage of life look like for the compliance profession?… Continue Reading
A federal grand jury in Brooklyn indicted an oil trader Tuesday for bribing officials in Ecuador.… Continue Reading
For compliance professionals and the programs they run, politically exposed persons are a big deal. PEPs trigger money laundering and corruption concerns and therefore attract enhanced due diligence. So, I always assumed PEPs are easy to identify.… Continue Reading
The DOJ released the first version of its Evaluation of Corporate Compliance Programs in 2017. That document (with its 2019 and 2020 updates) completed the chief compliance officer’s amazing transformation from part-time generalist to today’s highly specialized “super executive.”… Continue Reading
The current troubles at McDonald’s Corp. — involving allegations that former CEO Steve Easterbrook had improper relationships with several employees, and that he and the HR department engaged in a mutual cover-up of improprieties — have again revealed how corporate boards are often overwhelmed by charismatic and strong-willed CEOs.… Continue Reading
The Treasury Department’s Financial Crimes Enforcement Network or FinCEN released new guidance this month that sets out its approach to enforcement practices and reassures financial institutions about the agency’s “clarity and transparency.”… Continue Reading
Here’s a head-scratcher. China is the country mentioned most often in FCPA enforcement actions — 63 times by my count. And yet, only one PRC-headquartered parent company has been the subject of an FCPA enforcement action.… Continue Reading
Critics and supporters shower attention on the FCPA’s affirmative defenses for local law and promotional expenses. And the facilitating payments exception is a rich vein for the FCPA commentariat. Why, then, is the FCPA extortion defense mostly ignored and neglected?… Continue Reading
Russia’s most prominent opposition leader and anti-corruption campaigner, Alexei Navalny, was reported Thursday to be critically ill after an apparent poisoning while on a flight from Siberia to Moscow.… Continue Reading
The Justice Department issued an FCPA Opinion Procedure Release Friday, the first new release since November 2014, advising a U.S.-based investment advisor that fees paid to a foreign government-linked investment bank’s affiliate wouldn’t trigger an FCPA enforcement action.… Continue Reading
I had a simple (and unoriginal) thought years ago that has helped me understand why compliance can be so difficult. My thought was that people will do whatever they’re paid to do.… Continue Reading
