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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

Corruption Risks — China Travel Edition (Part I)

In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading

Diageo’s ‘Rice Cake’ Payments

There’s always a danger that an unhealthy corporate practice, even an illegal one, will gain internal acceptance and legitimacy simply because it happens all the time.

Take Diageo’s gift giving in Asia.… Continue Reading

Asian Values, FCPA Risks

By Michael S. Diamant

Few FCPA compliance challenges are as vexing as the provision of everyday business courtesies, like gifts, meals, drinks, travel, and entertainment. Because the FCPA has no de minimis threshold, even minor expenditures could implicate the statute’s anti-bribery and accounting provisions.… Continue Reading

Enforcement Report For Q3 ’09

During the third quarter, we counted Foreign Corrupt Practices Act enforcement actions involving nine individuals and five corporations. Among the developments: Three FCPA-related trials were completed, all ending badly for the defendants (Bourke, Jefferson and Green).Continue Reading

Juiced Up Enforcement

For those who missed any of the FCPA enforcement news during the recent hyper-active stretch, here’s what happened:

July 28 — Label-maker Avery Dennison Corporation resolved civil and administrative charges brought by the Securities and Exchange Commission.… Continue Reading

Aon’s New Path

A couple of months ago, guest-blogger Scott Moritz talked about risk-based compliance. His post, we now see, was prophetic. Why? Because just last week, when Aon settled an enforcement action with the U.K.’s… Continue Reading