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
Last month, French firm Safran S.A. received the DOJ’s 16th declination with disgorgement. Remember how declinations with disgorgement came into being?… Continue Reading
This post is about internet censorship. That, ironically, is a prohibited topic under China’s rapidly expanding censorship regime. Because I’ll talk about SEC registrants who warn investors about China’s internet censorship as a risk factor, that’ll likely add to the illegality.… Continue Reading
Leaks of offshore corporate records have gained enormous popularity and continue to grow in scope and scale. The Pandora Papers, Paradise Papers, Bahamas Leaks, and Panama Papers have triggered investigations into kleptocrats, oligarchs, and public officials who failed to disclose their assets.… Continue Reading
Because of Covid-19, nearly half of all U.S. workers are now working from home, and a majority of those want to continue working from home after the outbreak ends. Have we reached the point when some employees will have a legally enforceable right to work from home?… Continue Reading
China has been mentioned in more than 60 FCPA corporate enforcement actions, including eight in 2019 alone. So FCPA practitioners have long been wary of potential problems there. And yet, with serious recent developments potentially impacting trade and on-the-ground operations, now is a good time to reassess China compliance risks.… Continue Reading
As the lockdown is slowly lifted, it’s becoming clear that workers aren’t going to rush back to their offices. Some will eventually return, but for others, working from home will be more or less permanent.… Continue Reading
Many of the recent posts on the FCPA Blog have dealt with various aspects of Covid-19: our very personal health concerns, enhanced bribery risks, enforcement, and the possible impact on the operation of compliance systems and compliance organizations in times of travel bans and budget constraints in many industries.… Continue Reading
When the coronavirus lifts, as it sometime will, our global supply chains and sales cycles will again ramp up. There will then be tremendous and well-intentioned pressures to start moving goods and services through the global economy, and much of that pressure will fall to the frontlines: folks and teams in procurement, supply chain management, and sales.… Continue Reading
At a Financial Industry Regulatory Authority Conference last month, regulators reportedly stated that they consider companies liable for breaches notwithstanding the types of technical or security models followed, regardless of whether the regulatory model placed the responsibility on the company or not.… Continue Reading
Last year just before the “big date” of May 25, I wrote a post trying to analyze GDPR provisions through the lens of the whistleblowing process. At that time there were many questions ranging from how the rules will apply to whistleblowing on a national level to how to balance individuals’ privacy rights against companies’ need to pursue investigations.… Continue Reading
It has been over three months since the EU General Data Protection Regulation (GDPR) went into effect. The sky hasn’t fallen, and we are still here. We at TRACE now wear a t-shirt saying “I survived the GDPR” and see the humor in GDPR jokes and online memes.… Continue Reading
The General Data Protection Regulation (GDPR) came into effect in May. With the risk of hefty fines, it’s no surprise that GDPR compliance tops the agenda for many organizations. But one area of technology faces even greater challenges under GDPR: blockchain.… Continue Reading
