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
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
PepsiCo produces some of the world’s most beloved drinks and snacks, including Pepsi, Gatorade, and Cheetos. With over 300,000 employees globally, how does its anti-bribery policy compare?… Continue Reading
As the year draws to a close, it’s time to recall the biggest stories from the FCPA Blog. Here are my choices for the top five stories we’ve covered during 2022, along with some personal favorites for honorable mention.… Continue Reading
The biggest FCPA resolutions yearly show enormous variation and no predictable pattern. Although four of the biggest cases for each of the past ten years settled for more than $1 billion, with an overall average settlement size for the ten cases of about $996 million, a couple of years were laggards.… Continue Reading
The UK subsidiary of Swiss mining giant Glencore was ordered to pay £281 million ($314 million) in the United Kingdom on Thursday for bribes in Nigeria, Cameroon, Ivory Coast, Equatorial Guinea, and South Sudan.… Continue Reading
Following recent SEC filings that described previously unreported FCPA-related investigations, there are at least 100 confirmed ongoing investigations overall, with 20 new active investigations first disclosed since the start of 2020, according to data from FCPA Tracker.… Continue Reading
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
So far in 2022, there have been four FCPA enforcement actions totaling $865 million in penalties and disgorgement. That pushes all-time FCPA resolutions over $24 billion.… Continue Reading
Glencore’s FCPA resolution last month included a plea agreement requiring the parent company’s Chief Compliance Officer to certify its compliance program and reports to the DOJ. The CCO’s certification is subject to the false statements statute, punishable by up to five years in prison, and the federal obstruction law, which carries a potential prison sentence of up to 20 years.… Continue Reading
The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading
When Switzerland-based Glencore paid the DOJ $700 million last week to settle widespread FCPA offenses, it earned a place on our FCPA top ten list, replacing a French bank and leaving Goldman Sachs as the only other bank currently on the list.… Continue Reading
Switzerland-based mining and commodities giant Glencore plc on Tuesday settled corruption investigations in the United States, the UK, and Brazil. In the U.S., subsidiary Glencore International AG pleaded guilty to one count of conspiracy to violate the FCPA and agreed to pay $700 million in criminal penalties and forfeiture.… Continue Reading
Multinational companies regularly hire agents and fixers to help them win lucrative business in complex or unfamiliar environments. These intermediaries, who include both established firms and well-connected individuals, provide introductions to decision-makers, intelligence on how to secure a contract, and an on-the-ground presence in far-flung lands.… Continue Reading
