News and commentary about white-collar crime, enforcement, and compliance
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
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
Compliance programs work most of the time because most people tend to respond in similar ways to similar circumstances. In behavioral science, those tendencies are sometimes called “effects.” Some effects can strengthen compliance programs; others can weaken them.… Continue Reading
Goal setting. We do it every day. Usually, we have multiple goals running at the same time. Finish a marathon, learn Italian, master the violin. Personal goals like those are healthy and keep us moving forward.… Continue Reading
Every compliance training session should include this warning: If you ever become involved with, see, or otherwise discover a potential FCPA violation, stop everything. Don’t clean your desk, empty the trash can, or clear your browser history.… Continue Reading
The current troubles at McDonald’s Corp. — involving allegations that former CEO Steve Easterbrook had improper relationships with several employees, and that he and the HR department engaged in a mutual cover-up of improprieties — have again revealed how corporate boards are often overwhelmed by charismatic and strong-willed CEOs.… Continue Reading
I had a simple (and unoriginal) thought years ago that has helped me understand why compliance can be so difficult. My thought was that people will do whatever they’re paid to do.… Continue Reading
On December 2, 2001, the world woke up with shocking news: Enron filed for Chapter 11 protection in the U.S. Bankruptcy Court for the Southern District of New York. Thus began one of the most important corporate fraud scandals in the history of capitalism.… Continue Reading
Recent media reports suggesting Rolls-Royce’s bribery settlement drove the engineering giant to a record £4.6 billion ($5.7 billion) loss are not factually accurate, and contribute to a misleading narrative that big companies are too fragile to be punished robustly for corruption.… Continue Reading
In my prior post for the FCPA Blog, I asked two questions about the unfolding VW scandal.
One of them is already on the way to an answer: What happened to the whistleblowers and the compliance officers at VW?… Continue Reading
Corrupt organizations expect employees to parrot one set of values, while at the same time understanding that the real priority is to subvert these values by paying bribes to win business, or looking the other way when issues arise.… Continue Reading
With so much to lose by going to trial, how many organizations and people will plead guilty to white collar crimes they didn’t commit? Ellen Podgor (left) of Stetson University College of Law and the White Collar Crime Prof Blog asks that question in her latest essay, “White Collar Innocence: Irrelevant in the High Stakes Risk Game.”… Continue Reading
Companies facing criminal indictment for violating the Foreign Corrupt Practices Act and other federal laws have a sure-fire way to help themselves. They can cooperate. Those found to have “fully cooperated” under the Federal Sentencing Guidelines are entitled to reduced penalties; most of them escape with a deferred or non-prosecution agreement.… Continue Reading
No one blames the New York Times Company. If the only way it can save its flagship New York Times is to shut down the Boston Globe, then the owner’s choice is easy.… Continue Reading