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
Corporate FCPA defendants hoping for declinations must demonstrate that they’ve performed a root cause analysis and remediated the underlying conduct. The DOJ doesn’t tell companies how to do the root cause analysis, and there are many methods to pick from — Scatter Plot Diagram, Fishbone Diagram, Failure Mode and Effects Analysis (FMEA), and Pareto Chart, among others.… Continue Reading
In March 2023, the DOJ Criminal Division revised its valuable Evaluation of Corporate Compliance Programs (ECCP) to emphasize two priorities for corporate compliance: (1) the preservation of communications made via personal devices and instant messaging apps and (2) compliance incentives and disincentives in executive compensation.… Continue Reading
PepsiCo produces some of the world’s most beloved drinks and snacks, including Pepsi, Gatorade, and Cheetos. With over 300,000 employees globally, how does its anti-bribery policy compare?… Continue Reading
Since its founding, the FCPA Blog has been a free resource used by compliance professionals globally. Today, we’re launching our Patreon, where you can show your support.… Continue Reading
How do public company audit committees cope? Their to-do list keeps getting longer and more complicated. Yet somehow, most audit committees still complete their tasks (which, by the way, include FCPA compliance oversight).… Continue Reading
The World Bank debarred a Vanuatu power and communication company Wednesday for fraudulent practices connected to a project in Vanuatu.… Continue Reading
FTX crypto-exchange founder Samuel Bankman-Fried was charged Tuesday in a superseding indictment filed in the Southern District of New York with 31 counts, including conspiracy to violate the anti-bribery provisions of the FCPA.… Continue Reading
Singaporean offshore and marine engineering group Sembcorp Marine — which acquired FCPA violator Keppel Offshore & Marine earlier this year — has disclosed an investigation into “alleged irregularities” related to its operations in Brazil.… Continue Reading
For criminals, what’s not to love about the art and antiquities market? There’s widespread secrecy surrounding beneficial owners and transactions, values that are subjective and wide-ranging, and an easily accessible and active marketplace.… Continue Reading
Miranda warnings or their absence are rarely a factor in FCPA cases. Most individuals accused of FCPA violations take plea deals, and what happens procedurally before the plea probably doesn’t matter later.… Continue Reading
The U.S. Treasury Department has been eager to establish a corporate ownership registry in its battle against dirty money. Those who have read my articles before on public registries know I have doubts about their effectiveness.… Continue Reading
It’s tax season in America. For law-abiding citizens and residents, that means meticulously counting income and deductions. For the crooks out there, the IRS wants you to know: If you received a bribe, you need to report it as income.… Continue Reading
