Skip to content


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

Posts Tagged: Disclosure

D&B Suspends Operations At China Unit

Dun & Bradstreet has temporarily suspended operations at Shanghai Roadway D&B Marketing Services Co Ltd. pending an investigation into potential violations of the FCPA and Chinese privacy laws.

Reuters reported that police in Shanghai ‘confiscated four computer servers at the unit’s headquarters and questioned three senior executives.’… Continue Reading

Avon Discloses SEC Investigation

Avon Products confirmed Thursday that the SEC has issued a formal order of investigation into possible violations of the Foreign Corrupt Practices Act.

Avon’s disclosure appeared in its quarterly report filed with the SEC.… Continue Reading

Oracle: Why No Public Disclosure?

According to a report Wednesday in the Wall Street Journal, Oracle has been the subject of a criminal bribery investigation centered on selling practices in Africa. FBI agents and DOJ prosecutors, the report said, have been looking into the allegations for more than a year.… Continue Reading

Are We All Issuers Now?

For years, critics have said the FCPA hurts U.S. financial markets by scaring away foreign companies that don’t want the burden of compliance. We don’t know of any hard evidence to support that argument, and no foreign executives have told us they’re staying out of American markets because of the FCPA.… Continue Reading

To Disclose or Not Disclose: That is the Question

By Michael Volkov

The Justice Department, the Securities and Exchange Commission and the FCPA bar spend extraordinary amounts of time discussing and explaining FCPA enforcement and compliance issues. But one of the most important issues never sees the light of day.… Continue Reading

America’s Newest Foggy Bottom

Just when we thought the SEC’s job is to regulate markets and protect investors, we’ve learned it’s all about, ahem, foreign policy. 

At least that’s the message in yesterday’s SEC release concerning proposed new rules under Dodd-Frank about the use of conflict minerals from the Democratic Republic of the Congo and adjoining countries.… Continue Reading

The Cost Of Certainty

Fomer federal prosecutor Michael VolkovDespite the might of the FCPA, the awesome firepower of the DOJ, and the best practices of the world’s most compliant companies, bribery will always be among us.… Continue Reading