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
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
When the first set of general corporate compliance program standards – the Federal Sentencing Guidelines for Organizations – was issued in 1991, there was no mention of risk assessment. More recent standards, however – including the “Evaluation of Corporate Compliance Programs” issued by the U.S.… Continue Reading
The DOJ’s new guidance for evaluating corporate compliance programs put the spotlight on organizational justice, or what we might simply call fairness.… Continue Reading
The Justice Department Monday published a new version of its guidance on how it evaluates compliance programs when making corporate charging decisions. … Continue Reading
One of the most significant developments in the ethics space in recent years is the recognition that “paper” programs don’t afford meaningful protection against misconduct or its consequences. Established companies such as Nissan and Pacific Gas & Electric and media companies reeling from #MeToo scandals generally have a compliance infrastructure of lawyers, Codes of Conduct, training and hotlines but nonetheless their CEOs and senior managers have behaved as if these safeguards didn’t apply to them.… Continue Reading
This month the UK Serious Fraud Office published new guidance about how it assesses the effectiveness of the companies it investigates. The SFO’s eight-page document “Evaluating Compliance Programs” arrived with very little fanfare late last week.… Continue Reading
During my time as a sales executive — working alone, remotely and thinly supervised — I sadly thought of my conduct as a win-win. My company enjoyed tremendous sales increases, my channel partners moved to the next opportunity, and often poorly paid public officials got a little something to make ends meet.… Continue Reading