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
When the DOJ and SEC published their FCPA Resource Guide, they emphasized the connection between remedial action and enforcement. The Guide makes clear that no company can expect a favorable FCPA resolution unless it takes adequate remedial action, and conversely, companies that fail to do that are more likely to face charges and harsher FCPA penalties.… Continue Reading
Both journalists and compliance professionals are gatekeepers. They have a similar duty to find and report the truth for the public welfare. So, thinking I could learn something, I searched for a code of ethics for journalists and found several.… Continue Reading
One of the least understood aspects of anti-corruption compliance outside the compliance community is that perfection isn’t required. Compliance involves people, and whenever people are involved, things get messy. Compliance professionals know it and so do the feds.… Continue Reading
The DOJ’s new guidance for evaluating corporate compliance programs put the spotlight on organizational justice, or what we might simply call fairness.… Continue Reading
In January, Airbus entered into a $4 billion global settlement to resolve bribery offenses. Why did the FCPA Blog assess Airbus’ FCPA penalty at about half that number for the top ten list?… Continue Reading
As the leader of a private company, WeWork’s former CEO Adam Neumann clearly wasn’t subject to strong expense reporting requirements or conflicts of interest processes — he threw extravagant parties, routinely hired his family members and close friends, and engaged in numerous related-party transactions.… Continue Reading
Last week the transcript from Tim Leissner’s August 28 plea hearing was unsealed and posted online, courtesy of the Financial Times.
Mr. Leissner was a managing director of Goldman Sachs and chairman of its Southeast Asia operations.… Continue Reading
The best primary source material for creating and maintaining an anti-corruption compliance program is still Chapter 8 of the U.S. Federal Sentencing Guidelines.
It describes the elements of an “effective compliance program” — a legal term of art with the specific meaning assigned to it by the Sentencing Guidelines.… Continue Reading
Former Louis Berger executive James McClung was sentenced this month to a year and a day in jail for violating the FCPA. If “a year and a day” sounds familiar, it should.… Continue Reading
Assistant Attorney General Leslie R. CaldwellAssistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.… Continue Reading
I’ve been attending the HCCA’s 19th Annual Compliance Institute this week in Lake Buena Vista, Florida.
The Health Care Compliance Association is a non-profit membership group for compliance professionals in the healthcare-provider field.… Continue Reading
Official expectations that companies will check to make sure that their compliance and ethics (“C&E”) standards are being followed have existed since the advent of the Federal Sentencing Guidelines for Organizations in 1991.… Continue Reading
