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
[…] “The C Suite: A Crucible for Misconduct.”
Looking back, I see that my thinking (and my language) changed because I was influenced by the release of the 2013 RAND Center’s 100-page report of a symposium on C-Suite misconduct.
It clarified the facts, provided a new vocabulary and inspired confidence to discuss hard realities. Later that year, […]
Charges Involve Fraud, FCPA Books and Records Violations and Improper Promotional Expenses Bermuda-based heavy equipment maker Ingersoll-Rand Company Limited said on October 31, 2007 that it resolved fraud and U.S. Foreign Corrupt Practices Act violations in connection with illegal payments by subsidiaries to Iraqi officials under the U.N. Oil For Food Program. Ingersoll-Rand will pay […]
In July 2008, the government of Iraq launched a massive FCPA-related federal lawsuit in New York City. We first talked about it here. The complaint named 93 defendants in claims alleging bribery and fraud under the now-defunct United Nations oil-for-food program. Iraq sought more than $10 billion in damages, describing the U.N. program as “the […]
[…] corruption is not overseas. It’s in the corner office.”
Misconduct at the top is now receiving the increased scrutiny it deserves. In a May 2013 symposium, the think-tank Rand Center for Corporate Ethics and Governance asked for analysis and recommendations from compliance experts and leading professionals from the SCCE, ECOA, high-level government officials, FCPA law […]
Ingersoll-Rand‘s deferred prosecution agreement was supposed to expire on Halloween. But the company is now reporting new potential compliance problems in China.
Larry Buterman (left) from Chadbourne & Parke’s New York office sent us an article he published in the Bloomberg Law Reports. It explains why the Justice Department’s enforcement actions in the U.N. oil for food cases don’t allege antibribery offenses under the Foreign Corrupt Practices Act. The reason: the kickbacks typically went directly to the […]
A friend of the court (amicus) brief explaining the fundamentals of compliance programs should be prepared, possibly by a new working group led by former DOJ and SEC officials, facilitated by the Rand Center for Corporate Ethics and Governance. The door is open for the […]
In a recent post, the FCPA Professor questioned the broad application of the label “declination” to any instance of FCPA scrutiny that does not result in an FCPA enforcement action.
[…] with retaliation, or when unsure in the tough situations, like how to deliver internal reports of wrongdoing to unreceptive top executives and directors. Donna convenes the annual RAND Symposium reports on strategy for this evolving profession.
Donna is a founder of Compliance Strategists, a leading consulting firm based in the metropolitan New York area specializing […]
In a post earlier this week, we added up the number of enforcement actions since 2005 against corporations and individuals. We’re searching for clues about how enforcement decisions are made, and whether corporate settlements might be replacing individual prosecutions. We eventually found 83 corporate actions and 106 individual prosecutions since 2005. But that didn’t tell […]
