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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

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: Brazil

The tenth anniversary of the Brazilian Clean Company Act: What’s ahead?

The Brazilian Clean Company Act completes ten years in 2023 and has fundamentally changed the compliance landscape in the country – undoubtedly, for the better. Transparency International Brazil published a survey this month of professionals from the most prominent Brazilian companies that reveals the importance of the Act, which 95 percent of the respondents approved.… Continue Reading

Ten years after the Clean Company Act, what’s changed?

On August 1, 2013, the Clean Company Act (Law 12,846) was enacted by the Brazil National Congress to fill a legal gap in the country’s anti-corruption enforcement power compared with laws like the FCPA and the UK Bribery Act, and standards set by the OECD anti-bribery convention.Continue Reading

Is the EU ramping up for criminal ESG enforcement?

The Environmental, Social, and Governance (ESG) sphere has dominated the international business and legal landscape in the past few years. ESG, which relates to non-financial performance indicators for an investment or a business, makes it possible to assess corporate actions’ impact on the earth in terms of sustainability and ethics.Continue Reading

Is the biggest global risk factor hiding in plain sight?

Last week I wrote about three global trends creating risk and exerting a powerful influence on compliance — population growth, swelling money supply, and proliferating regulation. There’s another global trend but it’s usually overlooked in conversations about risk and compliance: urbanization.… Continue Reading

‘Authorizing’ is at the center of most FCPA cases

Corporate subsidiaries only act on someone else’s say so. The drafters of the FCPA knew that, and that’s why the FCPA prohibits offering to pay, paying, promising to pay, or authorizing the payment of money or anything of value to a foreign official for an improper purpose.… Continue Reading

Airline pays reduced $41.5 million to settle FCPA offenses

Brazil airline GOL Linhas Aéreas Inteligentes S.A. agreed to pay the DOJ and SEC $41.5 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to officials in Brazil to pass legislation benefitting the company.Continue Reading

Is your ‘business rationale’ for intermediaries fact or fiction?

Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading