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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

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: Glencore

My picks for our top stories of 2022

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

These are the biggest FCPA cases for each of the past ten years

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

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

Sorry, CCO certifications are a rotten idea

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

Country count for the top ten list

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

Glencore pays $700 million to resolve widespread FCPA offenses

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

Will extractive companies move away from corruption-prone intermediaries?

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