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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

Management can own honesty or deceit. So pick one

At Fresenius Medical Care, according to a recent post on the FCPA Blog, management owned the graft and senior executives directed the bribery and the global cover up. The failures were both wide and deep, where “legal, compliance, and internal audit functions failed to detect and prevent the bribery,” the company said in an SEC filing.… Continue Reading

Are settlements a deterrent or a dodge?

The DOJ has unveiled new guidance to federal prosecutors about bringing criminal cases against individuals in instances of corporate wrongdoing.

The Yates Memo states that if a corporation wishes to resolve its own criminal charges and receive any credit for cooperation, it must provide the DOJ with all relevant facts relating to the individuals responsible for the misconduct.… Continue Reading

Judge accepts BNP guilty plea for sanction offenses

BNP Paribas pleaded guilty Wednesday to a charge of violating U.S. economic sanctions by processing transactions for clients in blacklisted countries, a development that a U.S. judge said should shows that no financial institution is “immune from the rule of law.”… Continue Reading

Who should pay for BNP’s crimes?

On June 30, the Justice Department and other federal and state agencies announced the long awaited settlement in the BNP case. The bank forfeited $8.8 billion and paid fines of $140 million for the “hat-trick of sanctions violations” — unlawfully offering the U.S.… Continue Reading

U.S. probes two French banks for possible sanctions, AML violations

French banks Societe Generale and Credit Agricole are being investigated by U.S. authorities for alleged money laundering and economic sanction breaches involving Iran, Cuba and Sudan.

The U.S. Treasury and Justice Departments, the Manhattan district attorney’s office and the New York Department of Financial Services are conducting the investigations, the Wall Street Journal reported on Friday.… Continue Reading