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
In February 2022, it was confirmed that a new UK offense of failure to prevent fraud will be prioritized, following the UK Law Commission report on corporate criminal liability in 2022.… Continue Reading
In January, Airbus entered into a $4 billion global settlement to resolve bribery offenses. Why did the FCPA Blog assess Airbus’ FCPA penalty at about half that number for the top ten list?… Continue Reading
A person with good manners might put it this way: On the topic of compliance officers, opinion is still divided. Others might just say that compliance officers are tolerated but never really liked, and for good reasons.… Continue Reading
When passed in 2010, the UK Bribery Act was dubbed the “most stringent anti-corruption legislation in the world.” This was due in part to Section 7, which created an unprecedented form of vicarious liability at the time, with a potentially strong extraterritorial reach.… Continue Reading
This month the UK Serious Fraud Office published new guidance about how it assesses the effectiveness of the companies it investigates. The SFO’s eight-page document “Evaluating Compliance Programs” arrived with very little fanfare late last week.… Continue Reading
Last year marked a key transition in the UK in relation to bribery enforcement. David Green departed from the SFO in April 2018 to be replaced (on an interim basis) by his COO, Mark Thompson, and finally succeeded in the autumn by Lisa Osofsky.… Continue Reading
The first contested “failure to prevent” case, in which a company sought to rely on having adequate procedures in place, concluded with a small British refurbishment company being found guilty.
Despite now being dormant, it was decided to be in the public interest to try the case and in doing so sends out a strong message that companies of all sizes should be considering whether they have what might constitute adequate procedures in place.… Continue Reading
Andy Spalding asked in a post on the FCPA Blog why countries that allow facilitating payments seem to have lower levels of corruption? He didn’t find a definitive answer. But I want to offer my own explanation of why countries that permit facilitating payments might have a better record than those that do not.… Continue Reading
Minnesota-based Image Sensing Systems said the DOJ has “closed its inquiry” into potential Foreign Corrupt Practices Act violations and the SEC has also closed its investigation.
The company said last week the DOJ decision not to bring an enforcement action cited its “voluntary disclosure, thorough investigation, cooperation and voluntary enhancements to its compliance program.”… Continue Reading
Head of the BBA, Sir Richard Lambert (courtesy of the BBA)The British Bankers’ Association recently issued its 2014 Anti-Bribery and Corruption Guidance, emphasizing the regulatory context and in particular the Financial Conduct Authority’s policies, recent thematic reviews and enforcement action.… Continue Reading
At a bribery and compliance confab last week in London, the SFO’s Alun Milford hit the reset button for the UK Bribery Act, warning that his law enforcement agency will start acting like .… Continue Reading
Three men charged under the U.K. Bribery Act will appear in a London court Monday.
They’re among four defendants connected to Sustainable AgroEnergy plc charged in a £23 milion fraud for promoting and selling bio fuel investment products to U.K.… Continue Reading
