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
Certifications are not the sexiest feature of compliance programs. However, they can and should play an important role in every program. This post will briefly review some of the key aspects of compliance certifications, including the related topic of honesty pledges.… Continue Reading
Chicago-based spirits maker Beam Suntory Inc. agreed Tuesday to pay the DOJ $19.6 million to resolve Foreign Corrupt Practices Act charges for improper payments by its Indian subsidiary.… Continue Reading
Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.… Continue Reading
The World Bank’s enforcement arm, the Integrity Vice Presidency (INT), signaled this month they are mirroring initiatives first put forth by U.S. law enforcement. Specifically, INT indicated that they are investing significant resources into formally evaluating companies’ compliance programs during an investigation.… Continue Reading
Last month, the Commodity Futures Trading Commission ordered JPMorgan Chase & Company and its subsidiaries to pay a total of $920.2 million for artificially manipulating market prices of precious metals by sending false signals to other market participants.… Continue Reading
São Paulo-based conglomerate J&F Investimentos pleaded guilty Wednesday to conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act for a scheme to bribe officials in Brazil. … Continue Reading
Last week, Sargeant Marine agreed to pay the DOJ $16.6 million to settle FCPA charges that it bribed officials in multiple South American countries. The bribes it paid in Brazil alone helped the company and its trading affiliate win Petrobras contracts worth $185 million.… Continue Reading
The Justice Department issued an FCPA Opinion Procedure Release Friday, the first new release since November 2014, advising a U.S.-based investment advisor that fees paid to a foreign government-linked investment bank’s affiliate wouldn’t trigger an FCPA enforcement action.… Continue Reading
As enforcement actions against corporate crime grow, so also have coordinated multi-jurisdictional settlements. These are arrangements involving two or more enforcement agencies from different countries wherein the participating agencies agree to cooperate in settling alleged corporate wrongdoing often using common corrective measures.… Continue Reading
LA-based Herbalife Ltd. has reserved $123 million to settle FCPA offenses, following the indictment last year of two company executives charged with spending $25 million on entertainment and gifts for Chinese officials.… Continue Reading
Before I walked into my first DOJ proffer session, the defense lawyer in my FCPA case said, “Richard, there are no guarantees here, and the Justice Department moves at its pace, not your pace.… Continue Reading
One of the most significant developments in the ethics space in recent years is the recognition that “paper” programs don’t afford meaningful protection against misconduct or its consequences. Established companies such as Nissan and Pacific Gas & Electric and media companies reeling from #MeToo scandals generally have a compliance infrastructure of lawyers, Codes of Conduct, training and hotlines but nonetheless their CEOs and senior managers have behaved as if these safeguards didn’t apply to them.… Continue Reading
