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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

FCPA defendants need an ‘adequate procedures’ defense, too

The Department of Justice recently updated and published its guidelines for evaluating corporate compliance programs in the FCPA context. The Guidelines are remarkably thorough, but the text is aimed principally at assisting prosecutors with charging decisions, setting sanction amounts, and crafting subsequent compliance obligations — rather than at the corporate entities that are expected to phase in those compliance programs.… Continue Reading

Heads up: The UK Government has an anti-corruption plan

Image courtesy of HM GovernmentOn December 18, 2014 the UK Government issued its long awaited “UK Anti-Corruption Plan.” The plan sets out over sixty action points for the Government and its partners, organized around four key themes of “Pursue,” “Prevent,” “Protect” and “Prepare.” … Continue Reading

What’s changed under the UK Bribery Act? Due diligence in mergers and acquisitions

Two years after the Bribery Act 2010 came into force, the hysteria surrounding the Act has abated. There are fewer media pundits pronouncing the end of UK plc as we know it and there are fewer newly invented “legal experts” opining on an area they knew little or nothing about but which they saw as a potential earner to fill the gaping hole left by declining litigation and commercial transactions.… Continue Reading

U.K. anti-corruption enforcement threatened by budget cuts

After the fanfare of the U.K.’s Bribery Act 2010, which was predicted to bring about a significant upswing in national and global anti-corruption enforcement, the Government has proceeded to cut the budget of the Serious Fraud Office (SFO), the main enforcement agency, from £50 million in 2008/9 to below £30 million for 2013/14.… Continue Reading

New Proposal For FCPA ‘Adequate Procedures’ Defense

Jon Jordan, a friend of the FCPA Blog, has just published a new article in the Stanford Journal of Law, Business & Finance.

It discusses the adequate procedures defense under the UK Bribery Act and explores suggestions for a similar kind of compliance procedures defense under the FCPA. … Continue Reading