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
During the past few tumultuous weeks, the idioms about “a bad apple” or “a few bad apples” have been heard often in relation to law enforcement practices in the United States.… Continue Reading
Our team has analyzed every known FCPA investigation and enforcement action to create a market-leading automated system built to meet or exceed all government compliance standards and requirements.
Features include real-time visibility of all compliance communications and document delivery, latest compliance material pulled from the ethiXbase content library, fully automated emails of new and scheduled compliance materials, tracking of all email delivery, handing, opening, and document downloading. … Continue Reading
The case was full of bad facts. For nearly ten years until late 2004, some $1.8 million in bribes went to foreign officials and private parties in South Korea and China.… Continue Reading
Perhaps the biggest, although not yet the loudest, international corruption story involves Siemens AG, the German electronics and electrical engineering giant. Siemens says it has identified “a multitude of payments made in connection with [consulting agreements] for which we have not yet been able either to establish a valid business purpose or to clearly identify the recipient.… Continue Reading
One consistent measure of a compliance culture is executive responsibility. In the case of Enron’s CEO, Jeffrey Skilling, there was little evidence of that. True, he was obligated to comply with the Foreign Corrupt Practices Act.… Continue Reading
“An Overview of the Organizational Guidelines” from the United States Sentencing Commission’s May 2004 release includes the following jaw-dropping statement:
… Continue ReadingCriminal liability can attach to an organization whenever an employee of the organization commits an act within the apparent scope of his or her employment, even if the employee acted directly contrary to company policy and instructions.
