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
ISO 37001– a new standard for anti-bribery management systems — slated to be published in late 2016, is expected to be more detailed and internationally recognized than similar guidance published to date.… Continue Reading
Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it. … Continue Reading
Heads up: The six-month anniversary in your new position will arrive in a flash.
If you were hired as part of your organization’s response to a serious corruption allegation, you may still be in fire-fighting mode at this point, but starting to emerge for air.… Continue Reading
Matt Kelly’s post for the FCPA Blog about ISO 37001 — the draft standard for anti-bribery management systems– was a helpful introduction. We’re both members of the ISO 37001 U.S. Technical Advisory Group.… Continue Reading
The DOJ and SEC haven’t used the word “scalable” to describe an effective compliance program. But they’ve described scalability when talking about what’s needed.
For example, part of the job of the DOJ’s new compliance counsel is to help “assess a company’s program, as well as test the validity of its claims about its program, such as whether the compliance program truly is thoughtfully designed and sufficiently resourced to address the company’s compliance risks.”… Continue Reading
In November 2012, the SEC and DOJ released a joint Resource Guide to the Foreign Corrupt Practice Act to much fanfare. While some FCPA practitioners found the Guide underwhelming, others considered it a “thoughtful attempt to .… Continue Reading
Dear FCPA Blog – Another anonymous tip for you: In the 7th episode of this season’s House of Cards, Claire Underwood (the first lady) is on Air Force One with a stack of papers on the table in front of her. … Continue Reading
Boards of directors in global companies are showing an increased interest in establishing financial crime committees and hiring notable experts to advise them.
Several well-publicized enforcement actions have provided the impetus by requiring companies to establish such board-level committees and add to their financial crime expertise.… Continue Reading
