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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

Two Minute Warning

Boy, were we wrong. Syriana deserves our top rating of 5 Red Flags — not as a movie, but as a compliance tool. A thoughtful reader set us straight. Our sincere thanks to Daniel, whose imaginative use of Syriana we heartily endorse.… Continue Reading

Cases We’ll Never Report

Not all Foreign Corrupt Practices Act violations make the news. Here are three reasons why:

Reason #1. Ignorance. Some companies don’t discover their own FCPA problems. It sounds improbable, but it happens.… Continue Reading

Justice For Corporate Defendants?

Nothing has increased the impact of the Foreign Corrupt Practices Act on corporations more than respondeat superior. That’s the legal doctrine by which companies are vicariously liable for crimes committed by employees acting within the scope of their employment–that is, within their actual or apparent authority and on behalf of the corporation.… Continue Reading

The Dog Ate Our Homework

We had a nice post ready for today. Really. Then we remembered the 11:59 p.m. deadline on May 31 for the 2008 TRACE International essay contest on fighting public bribery. There were only a few hours to go so in desperation we sent our post off as our entry.… Continue Reading

Fear And Greed And The FCPA

We’ve noticed that when prices for energy and other commodities climb, there’s more public corruption. Spiking prices, after all, mean fatter margins for producers and proportionately more insecurity for consumers. Meanwhile, middlemen see nothing but opportunities.… Continue Reading

A Little Help From Our Friends

Our subject is always some aspect of the the Foreign Corrupt Practices Act. So around here the U.S. Department of Justice and the Securities and Exchange Commission get lots of attention.… Continue Reading

Joint Venture Compliance

International joint ventures bring very high risks under the U.S. Foreign Corrupt Practices Act. Unreliable partners — those who might pay bribes to foreign officials to help the business — need to be spotted early and either avoided or controlled.… Continue Reading

Termites In China

The happy people in the photo are Ma Wen (right), head of China’s new National Bureau of Corruption Prevention, and her deputy, Qu Wanxiang. The occasion is the official unveiling of the anti-corruption bureau in Beijing on September 13, 2007.… Continue Reading

With Friends Like These . . . .

The U.S. Foreign Corrupt Practices Act prohibits both direct and indirect corrupt payments to foreign officials. Indirect payments typically pass through the hands of an overseas partner or agent, then end up with the foreign official for an unlawful purpose.… Continue Reading

Compliance Guidelines

Many come to The FCPA Blog seeking compliance guidelines. That’s good, because our aim is to help people comply with the U.S. Foreign Corrupt Practices Act. Some seekers, however, have noticed that our posts and resources don’t include any out-of-the-box compliance programs, at least not yet.… Continue Reading