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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

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

Anti-Corruption Benchmarking Report As A Self-Assessment Tool

U.S. enforcement officials – including the Attorney General himself – have stressed the importance of self-assessments to achieving anti-corruption compliance program efficacy. Such assessments are also an important part of anti-corruption compliance program standards issued by the UK Ministry of Justice and the OECD anti-bribery working group.… Continue Reading

The Sentencing Guidelines: Field Notes On A 20-Year Experiment

Next Tuesday marks the twentieth anniversary of the Federal Sentencing Guidelines for Organizations, and their highly influential compliance and ethics program standards.

Because these standards are now well-established, it is easy to forget just how path breaking the Guidelines approach ― which entails providing both guidance and incentives for compliance programs ― was at the time.… Continue Reading