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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

Is The Government Listening?

By T. Markus Funk and Caryn Lara Trombino

U.S. enforcement efforts lead the charge against global public corruption. But as recent posts on the FCPA Blog suggest, America’s efforts are still, in many ways, a work in progress.… Continue Reading

The SEC’s Tricky Balancing Act

By Shruti Shah and Robert N. Walton

How the controversial whistleblower incentive provisions in the Dodd Frank Act will be implemented became slightly clearer last Wednesday. The SEC’s proposed new rules, available here, set the stage for the issuance of final rules next spring.… Continue Reading

Our Own Backyard

By Robert N. Walton & Michael L. Whitener

In its recent report on U.S. compliance with the OECD Foreign Bribery Convention, the OECD Working Group tasked with the review gave the U.S.… Continue Reading

Bribery Act Guidance Released

By Thomas Fox

The U.K. Ministry of Justice has released its “Consultation on guidance about commercial organisations preventing bribery (section 9 of the Bribery Act 2010).” As required by the Act, it provides guidance to “support businesses in determining the sorts of bribery prevention measures they can put in place.”… Continue Reading

Defending The Defense

By Thomas Fox

I want to thank Kyle Sheahen for his recent post and paper arguing that the promotional expenses defense under the FCPA is illusory. His work has stimulated a useful debate.… Continue Reading

The Enforcement Gap

By Nancy Z. Boswell and Robert N. Walton, Transparency International-USA

Transparency International’s sixth annual report on enforcement of the OECD Anti-Bribery Convention, released last week, paints a mixed picture. On the positive side, it shows active enforcement in seven of the 36 countries evaluated, including the U.S,… Continue Reading

A Failure To Escalate

By Thomas Fox

At the recent Corporate Counsel Institute – Europe put on by the Georgetown University Law CLE program in London, participant Matthew King, Group Head of Internal Audit at HSBC, was interviewed by Project Counsel founder Gregory  Bufithis.… Continue Reading

Asian Values, FCPA Risks

By Michael S. Diamant

Few FCPA compliance challenges are as vexing as the provision of everyday business courtesies, like gifts, meals, drinks, travel, and entertainment. Because the FCPA has no de minimis threshold, even minor expenditures could implicate the statute’s anti-bribery and accounting provisions.… Continue Reading

What Boards Should Ask

By Jeffrey M. Kaplan and Rebecca Walker    

As discussed in Part Two of this post, the U.S. Sentencing Commission recently approved changes to the compliance-and-ethics (“C&E”) program-related provisions of the Federal Sentencing Guidelines for Organizations.… Continue Reading

Why Boards Should Listen

By Jeffrey M. Kaplan and Rebecca Walker

As discussed in Part One of this post, the U.S. Sentencing Commission approved changes to the compliance-and-ethics (“C&E”) program-related provisions of the Federal Sentencing Guidelines for Organizations in April, one of which concerns steps companies should take after the discovery of criminal conduct.… Continue Reading