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
The DOJ and SEC have prosecuted 240 different companies (by my count) for FCPA offenses. Of those 240 companies, 13 have been repeat FCPA defendants. That means the recidivism rate for all corporate FCPA defendants is about 5.5 percent.… Continue Reading
A few weeks ago, I read about an “exasperated federal judge” at the sentencing of Samuel Mebiame, the 43-year-old son of the former prime minister of Gabon, who was an intermediary for Och-Ziff. … Continue Reading
The OECD is hosting an Anti-Bribery Ministerial meeting Wednesday (March 16) to discuss how to strengthen implementation of its Anti-Bribery Convention. One of the issues on the table for discussion is how to encourage voluntary disclosure by companies of wrongdoing and how settlements can be used to do that.… Continue Reading
In a New York Times op-ed, former assistant U.S. attorney Eric Havian recommended using better methods to deter corporate misbehavior. “Exclusion,” he said, “needs to be dusted off, modernized and used more frequently.”… Continue Reading
The story of Vicente Garcia, SAP’s former head of sales for Latin America, reminded me of one of the darkest periods in my life — the time before sentencing.
Garcia pleaded guilty last week to a one-count criminal information charging him with conspiracy to violate the FCPA’s antibribery provisions.… Continue Reading
During a recent anti-bribery panel in New York City, I was asked why I talk about my former corrupt behavior and the time I served in federal prison. “Why don’t you put it all behind you?”… Continue Reading
This is the second post in a series on the theories of criminal punishment on which modern anti-bribery enforcement is based. Part One is here.
Deterrence. It’s been called the holy grail of criminal punishment.… Continue Reading
This is the first post in a series on the theories of criminal punishment on which modern anti-bribery enforcement is based.
Deterrence — most of us would agree that it’s the goal of FCPA enforcement.… Continue Reading
