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Editors

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

Julie DiMauro: Best practices for today’s CCO

Let’s start this discussion with: Know the business.

In addition to knowing their regulatory-reporting obligations, compliance officers should understand what their managers do, what products and services their company offers and the systems that sustain these products and services.… Continue Reading

The DOJ Pilot Program: Financial considerations for both companies and their executives

The DOJ Fraud Section’s recently released FCPA Enforcement Plan and Guidance outlines a novel one-year pilot program for corporate self-reporting and cooperation, with specific fine reduction incentives.

“Appropriate remediation” is one of the pre-requisites for qualifying for these incentives, focused largely on compliance program characteristics and other preventive measures.… Continue Reading

Brooke Hopkins: But is your compliance program scalable?

The DOJ and SEC haven’t used the word “scalable” to describe an effective compliance program. But they’ve described scalability when talking about what’s needed.

For example, part of the job of the DOJ’s new compliance counsel is to help “assess a company’s program, as well as test the validity of its claims about its program, such as whether the compliance program truly is thoughtfully designed and sufficiently resourced to address the company’s compliance risks.”… Continue Reading

Are compliance officers crazy?

The verdict of history is unanimous: human beings can find trouble anywhere, and always do. We’re geniuses when it comes to messing things up.

For compliance officers, that means there will always be work to do.… Continue Reading