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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

‘Authorizing’ is at the center of most FCPA cases

Corporate subsidiaries only act on someone else’s say so. The drafters of the FCPA knew that, and that’s why the FCPA prohibits offering to pay, paying, promising to pay, or authorizing the payment of money or anything of value to a foreign official for an improper purpose.… Continue Reading

Reframing accountability to meet the new DOJ guidance

New and old corporate dishonesty stories, such as Theranos, Wirecard, and Wells Fargo, highlight a fundamental weakness. Irrespective of the industry or the business maturity, the wrongdoing escalates when the lines of defense that should protect the organization from risk become Teflon barriers to any accountability process.Continue Reading

How can Lisa Osofsky save the Serious Fraud Office?

Last week, SFO head Lisa Osofsky told British lawmakers that she regretted the agency’s “damaging relationship” with an American private investigator during a major corruption probe into oil consultancy Unaoil, which ultimately led to three UK convictions being overturned.… Continue Reading

Hitting the FCPA wall and finding the true center of my life

At 50, I sat in prison for violating the FCPA, among other offenses, due to no one’s fault but my own. At 40, I had sunk deep into the throes of drug addiction, which is not why I landed in prison at 50, but the addiction was a step in a series of awful decisions and contributed to my sense of narcissism and impunity.… Continue Reading

Back to FCPA Basics: Who’s a foreign official?

An FCPA anti-bribery offense requires five essential elements: (1) Corruptly (2) paying or promising to pay (3) anything of value (4) to a foreign official (5) for the purpose of obtaining or retaining business or securing any improper advantage.… Continue Reading

Do compliance officers have to speak English?

When you look at the numbers, the dominance of English as our lingua franca isn’t apparent. Out of the world’s total population of 7.5 billion people, about 1.5 billion can speak English, and just 400 million of them are native English speakers.… Continue Reading