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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

Sundar Narayanan: Is your next compliance problem at a toll booth in Delhi?

Delhi recently started enforcing new traffic regulations to reduce pollution levels. In October 2015, the city — properly the National Capital Territory, where 10 million people live — imposed a Green Tax on vehicles. 

The Green Tax (formally known as an Economic Compensation Charge) is supposed to be collected by the toll collection agencies at 124 entry points to Delhi.… Continue Reading

Does the prohibition on facilitating payments correlate with higher levels of corruption? A question revisited

In a prior post on the FCPA Blog, we observed a pattern that surprised ourselves and many others: signatories to the OECD Convention that allow facilitating payments have a significantly better average ranking on the Corruption Perceptions Index than those countries that prohibit them. 

Several readers, apparently no more comfortable with this statistic than we were, suggested other correlations worth exploring. 

My excellent research assistant at the University of Richmond School of Law, Dust Knight, and I tried a few.… Continue Reading

Don’t miss it. New guidance on grease payments

A few countries — including Australia, New Zealand, South Korea and the U.S. — allow grease payments that happen overseas. But the small bribes are still risky and potentially damaging. 

They’re almost always illegal under local law.… Continue Reading

In SEC v. Jackson and Ruehlen, judge denies everyone’s motions

Federal district judge Keith B. Ellison denied motions for summary judgments filed by the SEC, and by former Noble executives Mark Jackson and James Ruehlen.

Jackson, Noble’s former CEO, and Ruehlen, the head of Noble’s Nigeria unit, asked Judge Ellison to rule that the SEC didn’t have enough evidence in the civil suit against them for a jury to decide they violated the FCPA.… Continue Reading

In search of clarity on the OECD and facilitation payments

Nicola Bonucci and Patrick Moulette recently posted a discussion of the OECD’s position on facilitation payments. I admire the work of the OECD greatly, and I personally support its position on these payments.  I’m no critic of either.  But in seeking to garner further support for the OECD’s position, their post employs a couple rhetorical devices that might be just a little confusing.… Continue Reading