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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

Posts Tagged: Facilitating Payments

Compliance Officers Troubled By Third-Party Risk

A new FCPA study from Kroll (a sponsor of the FCPA Blog) found that the majority of corporate compliance officers at U.S. multinationals believe they’re exposed to bribery risk and fall short on best practices when it comes to third party screening, facilitating payments, and political donations.… Continue Reading

Small Bribes Cause Big Flap

There’s no exception in the FCPA for ‘small’ (de minimus) bribes. The statute outlaws any payment or promise to pay anything of value.

Because the de minimus standard isn’t there, critics call the FCPA impractical and out of step with the way the world really works.… Continue Reading

Facilitation: A Jury Question

Payments to government employees in exchange for the performance of a non-discretionary function such as issuance of a license or a permit occur far more often than bribes to government officials in exchange for assistance in winning a government contract.Continue Reading

Clinton Blasts Facilitating Payments

Secretary Clinton in Lusaka, Zambia on June 10, 2011All bribes — even grease payments to customs officials — hurt economic growth, Secretary of State Hillary Clinton told her audience at last week’s African Growth and Opportunity Forum in Zambia.… Continue Reading

Best Anti-Corruption Ad

The Super Bowl commercials were great. Our favorites were VW’s The Force and Bud’s Tiny Dancer. 

What about anti-corruption ads? None made it to the Super Bowl this year. But there are some goods ones out there. … Continue Reading

The UK Anti-Bribery Act: Let’s Cool Down the Hysteria

Michael Volkov believes UK prosecutors will act reasonably.By Michael Volkov

The year 2010 was another record-setting year for anti-bribery enforcement. Headline after headline reported yet another bribery scandal with the usual results: corporate fines, jail sentences, new and aggressive law enforcement strategies.… Continue Reading

Britain’s FCPA Plus

Photo by Steve PunterBy Thomas Fox

The U.K. Bribery Bill, introduced in March 2009, is still on track to pass out of Parliament before the upcoming general election, expected to be in June.… Continue Reading