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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
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Marc Alain Bohn
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Bill Waite
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Shruti J. Shah
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
Contributing Editor

All posts by Jeffrey Kaplan

Behavioral ethics and ‘middle-aged’ compliance programs

Last November marked the thirtieth anniversary of the Federal Sentencing Guidelines for Organizations. Whether or not this officially constitutes middle age, it underscores that the government’s policy of promoting compliance & ethics (C&E ) programs is no longer “developmental,” which is how the Chair of the Sentencing Commission described it in those early days.Continue Reading

Five ways to make the most of risk assessment

When the first set of general corporate compliance program standards – the Federal Sentencing Guidelines for Organizations – was issued in 1991, there was no mention of risk assessment. More recent standards, however – including the “Evaluation of Corporate Compliance Programs” issued by the U.S.Continue Reading

Where’s the harm in conflicts of interest?

There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment in the public realm.… Continue Reading

Mapping the World of ‘Compliance Checking’

Official expectations that companies will check to make sure that their compliance and ethics (“C&E”) standards are being followed have existed since the advent of the Federal Sentencing Guidelines for Organizations in 1991.… Continue Reading

‘Do I need to quit my job?’

This is a question that many compliance and ethics (C&E) officers have asked themselves when faced with management’s refusal to implement compliance program recommendations. And over the years, quite a few have answered the question in the affirmative (although, for obvious reasons, they are rarely eager to advertise the fact).… Continue Reading