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Editors

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

How important for compliance is remedial action?

When the DOJ and SEC published their FCPA Resource Guide, they emphasized the connection between remedial action and enforcement. The Guide makes clear that no company can expect a favorable FCPA resolution unless it takes adequate remedial action, and conversely, companies that fail to do that are more likely to face charges and harsher FCPA penalties.… Continue Reading

Five reasons ‘quiet quitting’ is bad for compliance

Quiet quitters, known during prior generations as corporate lifers, survivors, zombies, and burned-out cases, are everywhere, at least judging by their social media presence. They’re what comes next after the Great Resignation — mainly younger corporate workers who stay on the job but do nothing extra, their purpose being to seek a better work-life balance, protect against total burnout, and keep from being exploited.… Continue Reading

Five ways politicians sabotage anti-corruption agencies

The UN Convention Against Corruption (UNCAC), ratified in 2005, endorsed the post-colonial idea of independent anti-corruption agencies as a best practice to fight graft at the country level. Today, around 60 countries have at least one independent anti-corruption agency.… Continue Reading

Is your ‘business rationale’ for intermediaries fact or fiction?

Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading