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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

How do compliance officers vote with their feet?

When a compliance officer needs to vote with his feet, the key ingredients to look for at the next job are, among other things, a chief compliance officer who reports to an independent board, and incentives or bonus pay for outstanding work. … Continue Reading

Hold the shark fin; I’m honest and humble

Image courtesy of WikipediaChina’s crackdown on corruption is having a positive impact in an unexpected way. It’s causing a drop in demand for shark fin soup — good news for those working to save sharks.… Continue Reading

Andy Murray wins (you can too)

His Wimbledon win Sunday broke the 77-year drought for U.K. men at the Championships. As sporting victories go, it’s up there with the Red Sox overcoming the 86-year-old Curse of the Bambino.… Continue Reading

New Russia law goes beyond FCPA, Bribery Act

A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.

The law, which was added as Article 13.3 of a broader 2008 Law on Combatting Corruption, is entitled “The Requirement of Organizations to Take Measures to Prevent Corruption” and provides that organizations are required to develop and implement measures to prevent corruption and states that such measures may include the following:

(1) designating departments and officers responsible for preventing bribery and related offenses;

(2) developing mechanisms for cooperation with law enforcement authorities;

(3) developing and implementing standards and procedures designed to ensure ethical business conduct;

(4) adopting a code of ethics and professional conduct for all employees;

(5) establishing means for identifying, preventing and resolving conflicts of interest; (6) preventing the creation and use of false and altered documents.

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Wal-Mart: A gap in the Guidance?

Photo courtesy of Wal-MartIn the new DOJ-SEC Guidance there is a hole big enough for a Wal-Mart truck to drive through.

The Guidance (pp. 17, 26, 52-65) has many hypotheticals to illustrate “Guiding Principles of Enforcements,” “Hallmarks of Effective Compliance Programs” and what violates the FCPA or securities laws.… Continue Reading

Tone at the top of the world

The Emblem of the Kingdom of Bhutan འབྲུག་རྒྱལ་ཁབ་In the global battle against graft, the weapon that’s most essential is also the one in shortest supply — political will.

Without it the fight is over before it starts, and corruption grows.… Continue Reading