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
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
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
They craft policies, train employees, oversee due diligence, perform risk assessments, and lead investigations. But there’s another compliance role that’s practically unknown: disciplinarian. … Continue Reading
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
Why is cooperation in corporate enforcement actions such a big deal? Because from the outside, most companies are a black box. Without help, it’s impossible to know what happens inside.… Continue Reading
Last month, on the same day the DOJ and SEC imposed $3.3 billion in financial penalties against Goldman Sachs for 1MDB-related FCPA violations, Goldman’s board announced a plan to claw back $174 million from former and current executives.… Continue Reading
An excellent post on the FCPA Blog last week from Matthew McFillin and Amanda Rigby of KPMG talked about Covid-19-caused government shutdowns, and delays companies are experiencing obtaining permits, licenses, visas, and the like.… Continue Reading
Critics and supporters shower attention on the FCPA’s affirmative defenses for local law and promotional expenses. And the facilitating payments exception is a rich vein for the FCPA commentariat. Why, then, is the FCPA extortion defense mostly ignored and neglected?… Continue Reading
The Justice Department issued an FCPA Opinion Procedure Release Friday, the first new release since November 2014, advising a U.S.-based investment advisor that fees paid to a foreign government-linked investment bank’s affiliate wouldn’t trigger an FCPA enforcement action.… Continue Reading
I had a simple (and unoriginal) thought years ago that has helped me understand why compliance can be so difficult. My thought was that people will do whatever they’re paid to do.… Continue Reading
The DOJ and SEC published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act Friday, updating for the first time the best government-produced FCPA guidance.… Continue Reading
Two very different groups of companies will emerge from the lockdown: thousands with liquidity problems and uncertain futures, and hundreds with piles of cash and an appetite for growth. That means there’s a coming surge in mergers and acquisitions.… Continue Reading
