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
Contracts between companies and third parties might be the usual bailiwick of lawyers. But any robust program should give compliance officers a chance to know what compliance-related language is in those contracts, or what’s missing, and have a voice in the contract approval process.… Continue Reading
As I spent some time this morning trolling through a few dozen articles and opinion pieces about the Unaoil scandal, I was drawn to a Huffington post article detailing the roles of two large commercial banks. … Continue Reading
While clear policies on charitable contributions are important, the controls implementing these policies are equally critical to an effective compliance program.
Which type or types of controls are used in emerging markets is a function of the local level of corruption risk, the nature of the company’s intended contribution, the nature of the company’s business, and the size and complexity of its business.… Continue Reading
At November’s 32nd ACI Foreign Corrupt Practices Act conference in Washington, DC, the DOJ’s new Compliance Counsel, Hui Chen, emphasized that compliance programs need to be real and not just paper programs. … Continue Reading
Companies increasingly understand the importance of strong vendor-compliance programs, but costly enforcement actions stemming from supply-chain mismanagement remain.
Two experts have a few training, monitoring and evaluating tips to share with us.… Continue Reading
In the recently released FCPA guidance, the DOJ devoted an entire chapter to its FCPA opinions procedure releases — when to ask for one, how to make a request, and how to use the answer.… Continue Reading
Our posts about extending codes of conduct to third parties (here and here) attracted some thoughtful comments from readers. We first heard from Pete from DC, an old friend of the FCPA Blog.… Continue Reading
We always enjoy it when Pete from DC drops by the blog. He’s a veteran compliance professional and thinks deep thoughts about the Foreign Corrupt Practices Act. Lately, he told us, he’s been thinking about audit rights — the kind mentioned in our recent post about joint ventures.… Continue Reading
International joint ventures bring very high risks under the U.S. Foreign Corrupt Practices Act. Unreliable partners — those who might pay bribes to foreign officials to help the business — need to be spotted early and either avoided or controlled.… Continue Reading
