Skip to content

Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

FINRA releases 2014 regulatory and exam priorities

On Thursday, the Financial Industry Regulatory Authority (FINRA) released its 2014 Regulatory and Examination Priorities letter to help firms review and enhance their compliance programs. FINRA emphasized that it will be examining for strong controls and compliance efforts in the areas covered in the letter, since they were deemed to pose significant risk to the investing public and the integrity of the markets.… Continue Reading

How do compliance officers vote with their feet?

When a compliance officer needs to vote with his feet, the key ingredients to look for at the next job are, among other things, a chief compliance officer who reports to an independent board, and incentives or bonus pay for outstanding work. … Continue Reading

Anti-Corruption (Back-to-School) Resource List

It’s that time of year again. Across the country, law students are thinking about paper topics for seminar courses and journal notes. Like last year, I am posting a list of resources that I provide to students every fall in the Anti-Corruption seminar that I co-teach with my colleague, Professor Chris Yukins. … Continue Reading

New Russia law goes beyond FCPA, Bribery Act

A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.

The law, which was added as Article 13.3 of a broader 2008 Law on Combatting Corruption, is entitled “The Requirement of Organizations to Take Measures to Prevent Corruption” and provides that organizations are required to develop and implement measures to prevent corruption and states that such measures may include the following:

(1) designating departments and officers responsible for preventing bribery and related offenses;

(2) developing mechanisms for cooperation with law enforcement authorities;

(3) developing and implementing standards and procedures designed to ensure ethical business conduct;

(4) adopting a code of ethics and professional conduct for all employees;

(5) establishing means for identifying, preventing and resolving conflicts of interest; (6) preventing the creation and use of false and altered documents.

Continue Reading