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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

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

How can ‘anything of value’ cost less than a cup of coffee?

Not long ago, it was common for smart-alecky lawyers at FCPA conferences to make a big deal about “anything of value” not being defined in the FCPA (as in, the FCPA prohibits “the payment, gift, offer, or promise of anything of value”) and there being no de minimis threshold for bribes.… Continue Reading

How confidentiality agreements obstruct compliance

Compliance requires lots of mid-course corrections. Those corrections are based on constant feedback that’s honest and accurate. That’s why attempts to impede feedback and complaints are always bad for compliance. And yet, confidentiality agreements (in their many different forms) are everywhere.… Continue Reading

Country count for the top ten list

The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading