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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 Guest Contributor

Anti-Corruption Training for Third Parties

By Jeffrey M. Kaplan and Rebecca Walker

For a variety of reasons, requiring training of agents and other third-party business representatives is among the most challenging aspects of having an anti-corruption compliance program.… Continue Reading

The Road To Corruption

By Richard E. Messick

A new World Bank study on corruption in the roads sector shows the challenges contractors and engineering firms working in developing countries face when trying to avoid being drawn into schemes that violate the Foreign Corruption Practices Act or the anti-corruption laws of other nations or both.… Continue Reading

Anti-Corruption Training For The Board

By Jeffrey M. Kaplan and Rebecca Walker

Is your board trained on anti-corruption law and compliance? Clearly, not every board should be trained on every compliance risk area.  But for high-risk areas, training may be advisable – both to help a board exercise program oversight in an effective manner and to defeat a Caremark claim should a compliance failure occur.… Continue Reading

In FCPA Sentencings, What’s A ‘Benefit Received’?

By Dr. Patrick Conroy and Dr. Graeme Hunter

Fines and disgorgements for FCPA offenses are based on the “benefit received” from a bribe.

With those penalties now reaching hundreds of millions of dollars and with increasing enforcement, it’s important to understand what effect a bribe had on profits, and to carefully establish what the but-for profits would have been without the bribe.… Continue Reading

Anti-Corruption Compliance Program Charters

By Jeffrey M. Kaplan and Rebecca Walker

Do you have a charter or similar document for your compliance program? Approximately 83% of the companies responding to date to the anti-corruption compliance program benchmarking survey we are conducting with the FCPA Blog do.… Continue Reading

Under The FCPA, Where Are Victim’s Rights?

By Jordan Maglich

As readers of the FCPA Blog know, the past few years have seen a dramatic rise in FCPA prosecutions. In 2010 alone, companies settling FCPA-related charges paid $1.8 billion in monetary penalties, nearly tripling the $641 million paid in 2009.… Continue Reading

Role-Based Anti-Corruption Training

By Jeffrey M. Kaplan and Rebecca Walker

In a column published earlier this year, the New York Times’ Ethicist was asked about the ethics of an employee’s skipping FCPA compliance training where the training seemingly bore no relevance to his or her actual job.… Continue Reading

Respecting Human Rights Through Due Diligence

The UN’s top expert on business and human rights, Harvard Professor John Ruggie. Photo courtesy of the European ParliamentBy John Ruggie

I’d like to elaborate on Jeff Kaplan’s post on March 31, which discussed the role of Compliance and Ethics Officers in enabling their companies to respect human rights.… Continue Reading