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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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Reader: When dealing with the DOJ, groveling helps

Dear FCPA Blog, Thanks for the post about cooperation with the DOJ, which quoted from a recent talk by the DOJ’s Leslie Caldwell. Unfortunately, my real world experience in FCPA investigations and cooperation has looked slightly different.

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Alistair Craig: In arbitration, how much transparency is enough?

[…] Partnership (TTIP) is currently exercising the EU parliament. Concerns have been expressed that if the handling of disputes between investors and government are kept private, there is a risk of private interests and determinations subverting sovereign and EU legislation. Wednesday, the EU Parliament passed a non-binding resolution, in an attempt to influence ongoing TTIP […]

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FCPA enforcement report for Q3 2015

[…] and internal controls offenses linked to payments in the African country of Guinea. In May this year, the company said the DOJ had closed its FCPA investigation without bringing any charges. Guilty Pleas Richard Hirsch (July 20), the former senior vice president of Louis Berger responsible for operations in Indonesia, Thailand, the Philippines, and […]

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Why ISO 37001? Because global enforcement has arrived

[…] wrote posts (here and here) for the FCPA Blog about ISO 37001 β€” the draft standard for anti-bribery management systems. Those posts were widely read and stimulated a lot of interest in the topic, along with many questions. Worth and Leslie are both members of the ISO 37001 U.S. Technical Advisory Group. That’s one […]

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Jessica Tillipman: The Ten Longest FCPA-Related Prison Sentences

The DOJ’s Yates Memo is nearly a year old. The anti-corruption and compliance communities are still wondering what impact it will have on individual responsibility for white collar crimes. That in turn has brought more interest about past prison sentences for FCPA offenses and what future defendants might expect when sentenced.

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Project Ethics & Compliance Officer (Bechtel – Riyadh, Saudi Arabia)

[…] Compliance Officer Employer: Bechtel Location: Riyadh, Saudi Arabia ______ Description Role Overview The Project Compliance Officer is responsible for administering the Bechtel Ethics and Compliance Program for company employees working on the Riyadh Metro Project in Saudi Arabia, a major Infrastructure project and Bechtel’s largest ever lump sum project. The position will be based in Riyadh.

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Allanna Skeels: Fraud against organizations shifts to the cyber realm

[…] from cyber fraud came to $81.3 billion in 2015 and exceeded losses in North America and the EU by about $20 billion. Asia accounted for more than a quarter of the $315 billion cost of attacks globally during this period. Reportedly, 90 percent of Asia-Pacific companies have been hit by some form of cyber-fraud […]

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Elisabeth Danon on the globalization of deferred prosecution agreements

[…] allegations. In 2014, the OECD reported that 69 percent of the cases successfully concluded by member countries since the adoption of the Anti-bribery Convention were resolved through a settlement. From the Italian β€œpattegiamento” β€” a plea-bargaining resulting in a conviction β€” to the U.S. deferred prosecution agreement, the notion of settlement encapsulates all types […]

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