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
One consistent measure of a compliance culture is executive responsibility. In the case of Enron’s CEO, Jeffrey Skilling, there was little evidence of that. True,
Strictly speaking, “materiality” should never be part of an FCPA discussion. A payment or promise to pay anything of value can violate the antibribery provisions,
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A Reuters report from August 26, 2007 quotes Noble Corporation as saying it has been unable to obtain or renew permits for five of its
Its jurisdictional reach is legendary, but understanding exactly why the FCPA’s coverage stretches so far and wide is not always easy. One explanation comes from
Textron Inc., without admitting or denying books and records and internal controls allegations, consented to the entry of a final judgment with the SEC permanently
“There are moral problems as well as legal problems that go far beyond simply the question of illegal payoffs to foreign officials. “There are questions
The press is reporting that the Department of Justice on August 21, 2007 appealed the dismissal of FCPA charges against three men in connection with
“Small Organizations.—In meeting the requirements [for an effective compliance program under the U.S. Sentencing Guidelines], small organizations shall demonstrate the same degree of commitment to
“An Overview of the Organizational Guidelines” from the United States Sentencing Commission’s May 2004 release includes the following jaw-dropping statement: Criminal liability can attach to
