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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

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Tom Fox: Compliance Lessons from Lindbergh the Engineer

[…] professional, can have on your compliance program. In Hampton’s book he quoted a report from the airplane manufacturer’s chief engineer that the presence of Lindbergh in the design and manufacturing process “was a most important factor in welding together the entire factory organization into one smoothly running team.” That may be the most important […]

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Did Bill Clinton violate the Foreign Corrupt Practices Act?

[…] a propaganda coup when he expressed support for Mr. Nazarbayev’s bid to head an international elections monitoring group, undercutting American foreign policy and criticism of Kazakhstan’s poor human rights record by, among others, his wife, then a senator.” “Within days of the visit,” the New York Times said, “Mr. Giustra’s fledgling company, UrAsia Energy […]

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The U.S. has a chance to target demand-side bribery with the CROOK Act

[…] and fair elections, separation of powers among the branches of government, rule of law, a market economy with reasonably equal access for all participants, equal protections for human and civil rights, political freedoms and private property rights. Corruption poses a threat to this social contract by eroding each of its elements and undermining public […]

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RIP Jeremy Pope (1938 – 2012)

[…] South Africa in 1986 and worked for Nelson Mandela’s release from prison. At the time of his Pope’s death, he was a member of the New Zealand Human Rights Commission. Pope also consulted with election commissions in Africa and Asia and advised the World Bank and United Nations on anti-corruption issues. And with his […]

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Tom Fox: Doing Compliance Master Training In New York City, November 28 and 29

[…] throughout your organization; training and using other corporate functions to facilitate cost-effective compliance programs. The Doing Compliance Master Class will be based around my book, Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program, which focuses on the creation, implementation and enhancement of a best practices compliance program. I will also use […]

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What is corruption? Depends on who’s looking

[…] could also view this patronage as various operations of a premodern system of communication now described as criminality. One might say that corruption survives in part as human nature (or as a feature of the social system’s environment as Luhmann might say) despite the differentiation of the modern political and legal systems of communication […]

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CareAll whistleblower awarded $3.9 million in FCA settlement

[…] Medicare.  As part of Wednesday’s settlement, CareAll and its affiliates agreed to comply with an enhanced and extended corporate integrity agreement with the Department of Health and Human Services-Office of Inspector General. Since January 2009, the Justice Department has recovered more than $23.1 billion through False Claims Act cases. More than $14.8 billion of […]

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The Compliance Paradox

[…] curve — at the beginning, somewhere near the middle, or already close to the end? As we often say in this space, compliance isn’t about math but human beings and how they behave. That’s why we think the FCPA will grow, as it has for the past five years, then ebb somewhat, then grow […]

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The view from Pyeongchang: On windmills and anti-corruption

[…] are far from completely eliminating their negative environmental impact. But guess what? If your goal is to completely eliminate corruption from the Olympics (or from any other human activity) you’re dreaming. Indeed, the economists would tell us we shouldn’t even try; it would be prohibitively expensive (can you imagine?). The realistic goal is not […]

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Practice note: Compliance controls for charitable giving

[…] use of funds, annual reporting, and audit rights. While the use of these enhanced provisions on recipients may vary based upon the circumstances, it is important to design the oversight so it is tailored to the nature of the interaction. It is generally good practice to include audit rights in the agreement to ensure […]

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