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
Following an intense debate on November 29, 2020, the “Responsible Business Initiative” was rejected by a majority of the Swiss cantons. Instead, a reform of the Swiss Code of Obligations and Criminal Code is most likely to enter into force.… Continue Reading
Vitol Inc., the U.S. affiliate of Geneva-based Vitol group, entered into a deferred prosecution agreement with the Department of Justice Thursday to settle two charges that it conspired to violate the anti-bribery provisions of the FCPA by bribing officials in Brazil, Ecuador, and Mexico.… Continue Reading
When the SEC launched its whistleblower reward program in 2011, many predicted a flood of FCPA complaints. That didn’t happen. From FY2012 through FY2020, the SEC logged over 40,000 tips overall, but just 1,667 FCPA tips, or an average of 185 a year.… Continue Reading
Certifications are not the sexiest feature of compliance programs. However, they can and should play an important role in every program. This post will briefly review some of the key aspects of compliance certifications, including the related topic of honesty pledges.… Continue Reading
Job Title: VP of Global Compliance
Employer: SharkNinja Operating LLC
Location: Needham, Massachusetts USA… Continue Reading
In times of global crises and economic hardship, such as the current one, the art market provides a safe haven. Investors tend to distrust financial products and turn to assets that are less affected by market volatility, including in the luxury and art industries.… Continue Reading
The Suspicious Activity Reports (SARs) that banks submit to overseers such as FinCEN, as part of their AML requirements, often contain information and financial intelligence that can jeopardize the safety and well-being of an organization or individual.… Continue Reading
At work, when a boss or colleague insults us, whether intentionally or not, we feel it. Our usual reaction? Clam up and retreat into our shell.… Continue Reading
Paris-based compliance consultancy Compliance For Good has translated the DOJ’s June 2020 Guidance for the Evaluation of Corporate Compliance Programs.
The unofficial translation includes both English and French and can be downloaded here.… Continue Reading
The global human rights agenda is gaining momentum with a number of jurisdictions, including the United States, Germany, Switzerland, and the EU currently working (or committed) to introduce mandatory human rights due diligence laws.… Continue Reading
Job Title: Legal Counsel – Compliance 
Employer: Amcor
Location: Buffalo Grove, Illinois USA… Continue Reading
Non-U.S. companies have long dominated the FCPA Blog Top Ten list, and currently occupy nine of ten places. That means the DOJ and SEC (no matter who’s in the White House) apply the FCPA unfairly, using it to “punish” mainly big, well-known foreign businesses, right?… Continue Reading
