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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

Search Results for: label/Private Right of Action – Page 2

Is Freedom From Corruption a Human Right? (Part 2 of 3)

In this series I’m making the case that we should now think of freedom from corruption as a universal human right. John Locke, whose political philosophy is the foundation of modern rights thinking, certainly thought of corruption this way. He just called it by a different name. But just as interestingly, diverse thought systems […]

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The European Court of Justice UBO ruling is a victory for controlled transparency

[…] now removed public access to the nation’s open UBO register. Other member states may follow suit.  This judgment should be welcomed. Public UBO registers are an affront to the right to privacy. They also rarely have the intended effect of increasing effective enforcement. The decision favours controlled over unlimited systems of transparency. This will serve to […]

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What did WeWork teach us about ‘private-company’ compliance?

As the leader of a private company, WeWork’s former CEO Adam Neumann clearly wasn’t subject to strong expense reporting requirements or conflicts of interest processes — he threw extravagant parties, routinely hired his family members and close friends, and engaged in numerous related-party transactions. But as Neumann and WeWork learned, those lax standards, often […]

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Mike Scher: Let’s hang together to fight graft

[…] They want the biggest bribe to win the business, not the best price, product or service. The way to stop the bribery arms race is for all of the competitors to refuse to pay the bribes. This collective action is the key to fighting local and global graft.   Acting collectively to resist corruption […]

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The False Claims Act: A primer for whistleblowers

[…] DOJ white paper. *     *     * The False Claims Act (FCA), 31 U.S.C. §§ 3729 – 3733 was enacted in 1863 by a Congress concerned that suppliers of goods to the Union Army during the Civil War were defrauding the Army. The FCA provided that any person who knowingly submitted false claims to the […]

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Prosecuting Private Overseas Corruption

[…] private parties. When did that become a federal offense? Well, it happened this year when the Justice Department indicted California valve-maker Control Components Inc. (CCI) and six of its former employees. Here’s how. They were all charged under both the FCPA and the Travel Act (18 U.S. C. §1952). The latter prohibits traveling between […]

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Petrobras smashes the top ten list (and we explain why)

[…] FCPA settlement in history Thursday after the DOJ and SEC assessed penalties and disgorgement totalling $1.78 billion. Petrobras’s non-prosecution agreement with the DOJ included a criminal penalty of $853.2 million. An SEC administrative order required disgorgement of $933.5 million. All of the disgorgement was offset by payments Petrobras had already made to the settlement […]

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