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
Extending compliance programs to subcontractors has always been tricky. Interfere too much, and your company becomes liable for whatever goes wrong. A hands-off approach won’t work either. When subs flake out, prosecutors blame the head-in-the-sand attitude for the damage.… Continue Reading
Within minutes of the FCPA becoming law, lawyers developed two compliance tools that were instantly popular and that companies still use today. Due diligence questionnaires and compliance certifications are short and easy to administer and evaluate.… Continue Reading
In a November 29 press release that was also part of an SEC filing, Walmart Inc. announced the impending retirement of CFO Brett Biggs. The release said Mr. Biggs, 53, who joined Walmart 22 years ago and became CFO in late 2015, will leave in January 2023.… Continue Reading
Goal setting. We do it every day. Usually, we have multiple goals running at the same time. Finish a marathon, learn Italian, master the violin. Personal goals like those are healthy and keep us moving forward.… Continue Reading
Compliance officers looking for ways to become even more disliked can try this: Insist on writing down and circulating around the C-suite every major compliance decision. Include background, facts, and reasons for “yes” or “no” decisions.… Continue Reading
There are bottlenecks everywhere. Chip shortages, missing workers, clogged ports, rising commodity prices, and yes (still), Covid-19. They’re all disrupting or threatening to disrupt supply chains. For compliance officers, it’s a perfect storm.… Continue Reading
A lot of credit for equating managing with math goes to the late Peter Drucker, pictured left. “What gets measured gets managed,” he said, and “If you can’t measure it, you can’t improve it.”… Continue Reading
I collect tidbits about FCPA enforcement. During good weeks, the tidbits come together for a post. Other times, they stubbornly remain random factoids. That’s what happened this week. No unified field theory of FCPA enforcement.… Continue Reading
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
