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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

Posts Tagged: Brazil

‘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

Glencore pays $700 million to resolve widespread FCPA offenses

Switzerland-based mining and commodities giant Glencore plc on Tuesday settled corruption investigations in the United States, the UK, and Brazil. In the U.S., subsidiary Glencore International AG pleaded guilty to one count of conspiracy to violate the FCPA and agreed to pay $700 million in criminal penalties and forfeiture.Continue Reading