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

Cannabis-Related Due Diligence: What are the red flags for corruption?

As long as U.S. federal law enforcement priorities remain the same, licensed cannabis operators are unlikely to be prosecuted if they are completely compliant with state laws. However, if the DOJ or state regulators discover that a license was acquired through corrupt means, the license will not provide any protection.… Continue Reading

TechnipFMC pays SEC $5 million to settle FCPA violations

TechnipFMC plc paid the SEC $5 million Monday to settle FCPA offenses related to bribing Iraqi officials to win business with state-owned oil companies.

The London-headquartered oil and gas company disgorged $4.3 million plus pre-judgment interest of $735,000 to the SEC. 

In an internal administrative order (pdf), the SEC charged TechnipFMC with violating the FCPA’s books and records and internal accounting controls provisions.Continue Reading

DOJ refines stance on ephemeral messaging apps

In December 2017, the DOJ first took aim at messaging apps in its FCPA Corporate Enforcement Policy, which required companies to prohibit employees from “using software that generates but does not appropriately retain business records or communications.”

Companies failing to do so could be disqualified from receiving full credit — e.g., the presumption of a declination — for timely and appropriate remediation in the context of cooperating with a government investigation into potential FCPA violations.… Continue Reading