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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

Will ISO 37001 become a box-checking formality?

My prior post for the FCPA Blog suggested that changes are needed to the ISO 37001 anti-bribery management system before countries, agencies, and companies move forward with large-scale adoption.

One of my suggestions in particular — that ISO replace certification with a process for obtaining reviews of compliance programs — attracted thoughtful opposing comments and some criticism.… Continue Reading

Forty-four ways to fix ISO 37001

We don’t know what will happen with ISO 37001. Will it flourish and become a global standard, or will it languish?  But there is certainly room to improve what we have been given.… Continue Reading

Joe Murphy: Do compliance programs work?

This has always been a challenging question: How do you prove that preventive work stopped something bad from happening?

Over the years one thing I have noticed is that people who have done compliance and ethics work have actual stories about getting calls from employees, or talking with them at training, or dealing with helpline calls, where we know our work has helped head off a violation. 

But the outside skeptics who have studied the field somehow seem disconnected from this on-the-ground reality.… Continue Reading

Joe Murphy: U.S. antitrust lawyers are nervous about ‘business-side enforcement’

In his post yesterday about “business-side enforcement,” Mike Scher made some good points. But here’s one big reason why “collective action” has not caught on in the U.S.: antitrust. We antitrust lawyers are very nervous about clients meeting and talking with competitors. 

We would fear two things: one, discussions would turn to anticompetitive practices, e.g., inside discussions. 

And two, we would expect the Antitrust Division to be suspicious and for any collective action to risk government action and private antitrust suits.… Continue Reading