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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

Foreign issuers beware: the FCPA’s accounting provisions aren’t limited to bribery

The SEC reminded foreign issuers on December 10 that accounting misdeeds not only constitute securities fraud, they can violate the Foreign Corrupt Practices Act. 

In an enforcement action that did not involve bribery of any kind, the SEC charged Agria Corporation, a Cayman Islands company headquartered in Hong Kong, with securities fraud for failure to properly value gains and losses in a transaction with an affiliated company in mainland China.… Continue Reading

For compliance databases, a ‘no hit’ isn’t a green light

The recent Cobham Holdings Inc. OFAC settlement highlights a limitation in due diligence software: Cobham’s screening partner ran a name through a database and received no hits.

The name was later found to be a variation of a hit from the OFAC sanctions list, but wasn’t picked up due to the limitations of the search parameters. Continue Reading

Five years ago, I was walking out of prison

Whenever I hear about an FCPA sentencing that involves time in federal prison, I think of the day in July 2012 when I faced the judge and learned my fate.

I recall so clearly the anxiety of standing before Judge Richard Leon in DC, knowing that before I left the courtroom a sentence would be pronounced which would have life changing consequences. … Continue Reading

Job: Director, Compliance Counsel

Job Title: Director, Compliance Counsel

Employer: Heron Therapeutics, Inc.

Location: San Diego, California USA

Description: This position supports the compliance function and will be responsible for assisting in the development, execution and continuous improvement of the compliance program to ensure compliance with all applicable standards, laws, and regulations, including without limitation the U.S.… Continue Reading

New book from ICC Netherlands by industry leaders (free download)

The ICC Netherlands launched its new book “Integrity, A Valuable Proposition” at the International Integrity & Anti-Corruption Conference earlier this month. The book discusses the state of affairs of integrity and accountability in both the public and private sector, and the continuous dialogue and development.… Continue Reading

Cleared by feds, but FCPA accusations leave lasting scars

In December 2012, a payment processing company based in Johannesburg called Net 1 UEPS Technologies, Inc. disclosed some bad news. The DOJ and SEC had launched FCPA investigations.

The feds wanted to know if Net1 paid bribes to win a contract from the South Africa Social Security Agency (SASSA).… Continue Reading