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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

Is your FCPA compliance disclosure compliant?

The SEC guards the integrity of U.S. markets and protects investors by requiring issuers to disclose material information about themselves and their directors and officers. However, the SEC doesn’t tell anyone what to say or how to say it.… Continue Reading

How big a problem is corporate FCPA recidivism?

The DOJ and SEC have prosecuted 240 different companies (by my count) for FCPA offenses. Of those 240 companies, 13 have been repeat FCPA defendants. That means the recidivism rate for all corporate FCPA defendants is about 5.5 percent.… Continue Reading

Don’t expect agents to keep quiet about bribes they pay

In nearly all FCPA enforcement actions, agents, consultants, suppliers, distributors, and partners — whether real or faux — have a hand in bribery. They make approaches to foreign officials, set up offshore shell companies, generate fake invoices, and move money through accounts they own or control.… Continue Reading

Do you know how KYC applies to FCPA risk assessment?

Know-your-customer is usually associated with anti-money laundering programs. Customers (or clients) with close ties to corrupt leaders, for example, are flagged as an AML risk. But KYC also applies to FCPA risk analysis, but in a very different way.… Continue Reading

State-Granted Monopolies: Are they your best (and worst) customers?

They are so familiar to those of us who follow FCPA enforcement actions that we’re likely to stop noticing them. Petrobras in Brazil, Corpoelec and PDVSA in Venezuela, Pemex and CFE in Mexico, Takilant in Uzbekistan, Sonangol in Angola, Alba in Bahrain, Telecommunications D’Haiti, 1MDB in Malaysia, and Pertamina in Indonesia.… Continue Reading

Was Amec Foster Wheeler ‘afraid’ of its agents?

It’s a strange scenario. How did London-based Amec Foster Wheeler (AFW) end up with agents in three different countries for a single, relatively small project in Brazil — including two agents disqualified by AFW’s due diligence and a third agent that AFW thought had lost influence?… Continue Reading

Why FCPA cover-ups are worse than the crime

Every compliance training session should include this warning: If you ever become involved with, see, or otherwise discover a potential FCPA violation, stop everything. Don’t clean your desk, empty the trash can, or clear your browser history.… Continue Reading