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
As a government outsider, it’s impossible to know why there hasn’t yet been any DOJ or SEC corporate enforcement of the FCPA under the current administration. Here are three possible reasons:… Continue Reading
How much has FCPA enforcement and compliance changed over the last decade? Ask anyone who’s been around, and they’ll probably say “a lot” or “completely.” Perhaps the most telling metric quantifying this change is the average size of a corporate FCPA resolution.… Continue Reading
In 2020, the DOJ and SEC brought FCPA enforcement actions against 12 companies and imposed financial penalties totaling a record $6.4 billion. For a comparison, in 2019, 14 companies paid a (then) record $2.9 billion to resolve FCPA cases.… Continue Reading
Non-U.S. companies have long dominated the FCPA Blog Top Ten list, and currently occupy nine of ten places. That means the DOJ and SEC (no matter who’s in the White House) apply the FCPA unfairly, using it to “punish” mainly big, well-known foreign businesses, right?… Continue Reading
During the third calendar quarter, there were three corporate FCPA enforcement actions with penalties and disgorgement totaling about $182.7 million.… Continue Reading
This is the second post in a series on the theories of criminal punishment on which modern anti-bribery enforcement is based. Part One is here.
Deterrence. It’s been called the holy grail of criminal punishment.… Continue Reading
