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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

Posts Tagged: FCPA Resource Guide

Is your ‘business rationale’ for intermediaries fact or fiction?

Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading

How can ‘anything of value’ cost less than a cup of coffee?

Not long ago, it was common for smart-alecky lawyers at FCPA conferences to make a big deal about “anything of value” not being defined in the FCPA (as in, the FCPA prohibits “the payment, gift, offer, or promise of anything of value”) and there being no de minimis threshold for bribes.… Continue Reading

Can we really ‘measure’ compliance?

A lot of credit for equating managing with math goes to the late Peter Drucker, pictured left. “What gets measured gets managed,” he said, and “If you can’t measure it, you can’t improve it.”… Continue Reading

How much compliance training is enough?

We know a lot about what the feds expect from compliance training. For example, from the Evaluation of Corporate Compliance Programs and the FCPA Resource Guide, we know training is a hallmark of a well-designed compliance program. … Continue Reading

Why FCPA cover-ups are worse than the crime

Every compliance training session should include this warning: If you ever become involved with, see, or otherwise discover a potential FCPA violation, stop everything. Don’t clean your desk, empty the trash can, or clear your browser history.… Continue Reading