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
Compliance requires lots of mid-course corrections. Those corrections are based on constant feedback that’s honest and accurate. That’s why attempts to impede feedback and complaints are always bad for compliance. And yet, confidentiality agreements (in their many different forms) are everywhere.… Continue Reading
The Texas-based oil and gas giant employs over 65,000 people and has refineries in 21 countries. At 18 pages, ExxonMobil’s anti-bribery policy is the second longest we’ve seen behind VW’s 36-page policy.… Continue Reading
In the past couple of months, sanction list screening has become one of the most critical compliance tasks. A single question has triggered much of the change: “Are my business partners and other third parties I deal with really sanctioned?”… Continue Reading
The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading
London-based consumer goods conglomerate Unilever employs around 150,000 people worldwide. It has over 400 brands, including Dove, Hellmann’s, Axe, Knorr, and Vaseline, and its employee anti-bribery policy is a single page.… Continue Reading
In Kigali, Rwanda from May 3rd to 6th, 20 anti-corruption agencies from 18 African countries attended the 12th Regional Conference of Heads of Anti-Corruption Agencies in Commonwealth Africa. This year’s conference was themed “Combating Corruption for Good Governance and Sustainable Development in Africa.”… Continue Reading
Oil and gas pipe manufacturer Tenaris paid the SEC $78 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to a Petrobras official in Brazil.… Continue Reading
The Evaluation of Corporate Compliance Programs, first published five years ago, is now one of the most important compliance tools, not only for the DOJ prosecutors it’s addressed to, but also for compliance professionals outside government.… Continue Reading
Regulators and private firms increasingly rely on technology to identify financial crimes. As detailed in a recent report by the United Nations Development Programme (UNDP), organizations can use artificial intelligence, machine learning, and other tools to prevent corruption and related forms of illicit finance. … Continue Reading
When Switzerland-based Glencore paid the DOJ $700 million last week to settle widespread FCPA offenses, it earned a place on our FCPA top ten list, replacing a French bank and leaving Goldman Sachs as the only other bank currently on the list.… Continue Reading
As the recent high-level and healthy debate on the FCPA Blog has shown, there are various ways to gather and analyze corruption-risk data at the country level, all of which have respective pros and cons but nevertheless are indispensable in our era of risk-based compliance decision-making.… Continue Reading
Switzerland-based mining and commodities giant Glencore plc on Tuesday settled corruption investigations in the United States, the UK, and Brazil. In the U.S., subsidiary Glencore International AG pleaded guilty to one count of conspiracy to violate the FCPA and agreed to pay $700 million in criminal penalties and forfeiture.… Continue Reading
