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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 Jessica Tillipman

Interview with Vincente Martinez of the CFTC Whistleblower Program: Part I

In 2010, the Dodd-Frank Act created whistleblower bounty programs in both the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC). While readers of this blog are familiar with the SEC’s program because of its impact on FCPA enforcement, they may not be as familiar with the CFTC’s program. … Continue Reading

We’re Sorry. You Have Reached A Number That Is Disconnected . . .

A colleague once told me a story about an unfortunate incident that occurred during settlement negotiations with a government agency. During his presentation designed to demonstrate his client’s robust compliance program, he mentioned that the client had an ethics hotline for employees to call and report misconduct.… Continue Reading

Suspension & Debarment Part III: Mechanics and Mitigating Factors

Now that we have firmly established that neither suspension nor debarment may be used to “punish” contractors, let’s go over the mechanics of FAR 9.4.

Suspension permits an agency suspension or debarment official (“SDO”) to temporarily exclude a contractor from the procurement system based on “adequate evidence” of a violation of the offenses listed at FAR 9.407-2 (such as bribery).… Continue Reading

Suspension & Debarment Part I: An Introduction

In this era of outsourced government, nothing strikes fear in the hearts of government contractors like the words “suspension” and “debarment.” Given recent legislative initiatives designed to increase the prominence and use of this tool, a company’s familiarity with the U.S.… Continue Reading

Wal-Mart’s Simple Lesson: Learn To Live With The FCPA

There’s a reason why you don’t see many of the biggest U.S.-based government contractors on the FCPA top ten list (e.g., Lockheed, General Dynamics, Raytheon, Northrup, Boeing, etc.). Not that they didn’t struggle with compliance during the early years of enforcement, but they moved quickly to update their compliance and ethics programs once they saw the tide of FCPA enforcement turning.… Continue Reading

The Misguided Call For Mandatory Debarment

The U.S. Government spent nearly $538 billion in Fiscal Year 2010 for goods and services provided by private contractors. The largest and most experienced Government contractors maintain sophisticated compliance programs to ensure they do not run afoul of stringent U.S.… Continue Reading