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Editors

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

Tom Fox: Compliance in the Age of Mercantilism

What does the failure of the Kraft Heinz attempted hostile takeover of Unilever portend for the greater world of global anti-corruption enforcement specifically and compliance programs more generally?

As with most business issues during the new administration, things are in flux.… Continue Reading

ISO 37001 is here. Will It Work?

On October 14, after four years of work involving the active participation of experts from 37 countries, the International Organization for Standardization issued ISO 3700, its standard for anti-bribery management systems.… Continue Reading

Worth MacMurray: The DOJ is emphasizing a ‘culture of compliance’

Leslie R. Caldwell, Assistant Attorney General for the Criminal DivisionThe DOJ’s FCPA Guidance and Enforcement Plan places significant emphasis on organizational culture. The section describing “an effective compliance and ethics program” includes “whether the company has established a culture of compliance, including an awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”… Continue Reading

Billy Jacobson on the New FCPA Guidance: DOJ swings and misses

On April 5 the DOJ’s Fraud Section of the Criminal Division released a policy document called The Fraud Sections’ Foreign Corrupt Practices Act Enforcement Plan and Guidance. The new Guidance is an attempt to bring greater transparency to the benefits corporations will achieve by voluntarily disclosing FCPA problems and fully cooperating with investigations of these problems. … Continue Reading

The DOJ Pilot Program: Financial considerations for both companies and their executives

The DOJ Fraud Section’s recently released FCPA Enforcement Plan and Guidance outlines a novel one-year pilot program for corporate self-reporting and cooperation, with specific fine reduction incentives.

“Appropriate remediation” is one of the pre-requisites for qualifying for these incentives, focused largely on compliance program characteristics and other preventive measures.… Continue Reading