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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

Sentencing Guidelines: What’s Changed?

By Jeffrey M. Kaplan and Rebecca Walker

In April, the U.S. Sentencing Commission approved changes to the compliance-and-ethics-program related provisions of the Federal Sentencing Guidelines for Organizations. Absent Congressional action to the contrary (which is quite unlikely), the changes will go into effect in early November.… Continue Reading

Here Come The Global Guidelines

By Jeffrey M. Kaplan

In 1991, the U.S. government established a compelling and original model for promoting legal compliance by businesses. The federal sentencing guidelines applicable to organizations — sometimes called the Corporate Sentencing Guidelines — offered companies both strong incentives for implementing compliance and ethics (“C&E”) programs and meaningful guidance on how to do so.… Continue Reading

Britain’s FCPA Plus

Photo by Steve PunterBy Thomas Fox

The U.K. Bribery Bill, introduced in March 2009, is still on track to pass out of Parliament before the upcoming general election, expected to be in June.… Continue Reading

Risk-Based Compliance: First Steps

Scott Moritz: Risk-based compliance can work, even for the world’s biggest companies. By Scott Moritz

Who are your highest-risk third parties and what are you doing about them? Most FCPA enforcement actions involve payments through agents and other intermediaries.… Continue Reading

Can Someone Explain The Phone?




Nice blog article recently [here] about Bulgaria and Romania! Having extensive experience dealing over there, I could not resist sharing this with you. I took the attached photo when I visited one of our customers…..

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Two Minute Warning

Boy, were we wrong. Syriana deserves our top rating of 5 Red Flags — not as a movie, but as a compliance tool. A thoughtful reader set us straight. Our sincere thanks to Daniel, whose imaginative use of Syriana we heartily endorse.… Continue Reading