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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

Panalpina’s Problems Keep Spreading

Schlumberger N.V., the world’s biggest oil and gas services company, is among the dozen or more firms in that industry being investigated in connection with Panalpina’s freight-forwarding and customs clearance practices.… Continue Reading

Ten Elements Of An Effective Compliance Program

The purpose of an “effective compliance program” is to prevent and detect criminal conduct. Why is this important? Because an organization that violates the U.S. Foreign Corrupt Practices Act but has an “effective compliance program” is eligible for a reduced sentence — by up to 95% of the statutory penalties.… Continue Reading

Counting Corruption

A friend from Nigeria, which appears on these pages for the wrong reasons all too often, visited us this week. He gives a face and a voice to the human cost of his country’s terrible twins, red tape and corruption.… Continue Reading

One Law,Two Parts

The question comes from Pune, India: Can a payment that is not a bribe – such as a facilitating payment – be the basis for a criminal violation of the U.S.… Continue Reading

Red Tape Round-Up

With the 17th National Congress of the Chinese Communist Party in full swing in Beijing, we thought it would be a good time to see what leaders there are doing about corruption.… Continue Reading

Looking Back At Johnson & Johnson’s FCPA Disclosure

The SEC’s just-announced investigation of several orthopedic device makers for possible violations of the U.S. Foreign Corrupt Practices Act (reported here) probably originated in February 2007. That’s when Johnson & Johnson said it had “voluntarily disclosed to the U.S.… Continue Reading

Termites In China

The happy people in the photo are Ma Wen (right), head of China’s new National Bureau of Corruption Prevention, and her deputy, Qu Wanxiang. The occasion is the official unveiling of the anti-corruption bureau in Beijing on September 13, 2007.… Continue Reading

Greetings, Comrade

A friend of The FCPA Blog who bunked in Singapore awhile and has since returned to Washington, D.C. asks: In a communist country, is everyone a government official?

The question is important because the U.S.… Continue Reading

With Friends Like These . . . .

The U.S. Foreign Corrupt Practices Act prohibits both direct and indirect corrupt payments to foreign officials. Indirect payments typically pass through the hands of an overseas partner or agent, then end up with the foreign official for an unlawful purpose.… Continue Reading