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
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
Federal prosecutors in Texas learned recently that a request under a mutual legal assistance treaty, or MLAT, can toll a statute of limitations for only so long. The decision by Judge Kenneth M.… Continue Reading
Both journalists and compliance professionals are gatekeepers. They have a similar duty to find and report the truth for the public welfare. So, thinking I could learn something, I searched for a code of ethics for journalists and found several.… Continue Reading
The London-based luxury brand is highly-regarded for its stylish clothes and cheerful bags. Founded in 1856, Burberry has become one of the most sought after high-end retailers in the world. How sweet is the aroma of its anti-bribery and corruption policy?… Continue Reading
Following recent SEC filings that described previously unreported FCPA-related investigations, there are at least 100 confirmed ongoing investigations overall, with 20 new active investigations first disclosed since the start of 2020, according to data from FCPA Tracker.… Continue Reading
We recently had a company-wide outing to the local gun range. Handling weapons is serious business. There are a lot of rules, and everyone needs to be in complete compliance or there can be serious consequences.… Continue Reading
The DOJ recently announced a policy that requires CEO and CCO certifications with FCPA settlements. A purpose of the new requirement is to empower CCOs. Unless the General Counsel is also the CCO, the General Counsel’s importance to compliance matters is not the focus.… Continue Reading
After getting caught ignoring its employees and cheating on the CPA ethics exam, EY has become the latest example of how industry and company-level mindsets can turn into corporate liabilities. The SEC slapped a fine of $100 million on the audit firm, making it clear in their enforcement action that it was punishing both the cheating and the firm leadership’s failure to serve as a gatekeeper.… Continue Reading
The Inter-American Development Bank (IDB) debarred a Brazilian construction company Thursday for a year and a half for corrupt and fraudulent practices related to a project in Brazil.… Continue Reading
What can a company do to convince prosecutors, regulators, and sentencing judges that it is committed to compliance? The question needs an answer because commitment is the feds’ threshold issue and the top-ranked hallmark when evaluating compliance programs.… Continue Reading
After three of the four convictions in the SFO’s Unaoil case were overturned, the UK attorney general launched a review into the agency. Last month, Sir David Calvert-Smith’s report was published, and it made for deeply uncomfortable reading for the SFO and its supporters.… Continue Reading
On August 8, 2007, the founder (and current editor at large) published the first post on the FCPA Blog, “Delta & Pine Land Company Settles FCPA Charges.” Before Siemens, Airbus, and Goldman Sachs, there was Delta & Pine Land Company.… Continue Reading
Compliance programs work most of the time because most people tend to respond in similar ways to similar circumstances. In behavioral science, those tendencies are sometimes called “effects.” Some effects can strengthen compliance programs; others can weaken them.… Continue Reading
