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
We’ve tabulated all countries reported in connection with the ten enforcement actions that comprise the latest FCPA Blog Top Ten list. Twenty-six different countries appear. Four of those countries are mentioned three times, and three appear twice.… Continue Reading
You may have noticed a risk factor in annual reports and SEC registration statements about “conflicting laws and regulations.” Once rare, the warning has become common, thanks to globalized operations and proliferating regulators.… Continue Reading
So far in 2021, not much has happened in the world of FCPA enforcement. No big fireworks. No splashy headlines. Is that good or bad?… Continue Reading
Because of Covid-19, nearly half of all U.S. workers are now working from home, and a majority of those want to continue working from home after the outbreak ends. Have we reached the point when some employees will have a legally enforceable right to work from home?… Continue Reading
As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.… Continue Reading
How much has FCPA enforcement and compliance changed over the last decade? Ask anyone who’s been around, and they’ll probably say “a lot” or “completely.” Perhaps the most telling metric quantifying this change is the average size of a corporate FCPA resolution.… Continue Reading
In 2020, the DOJ and SEC brought FCPA enforcement actions against 12 companies and imposed financial penalties totaling a record $6.4 billion. For a comparison, in 2019, 14 companies paid a (then) record $2.9 billion to resolve FCPA cases.… Continue Reading
There have been a dozen corporate FCPA enforcement actions this year, including two of the biggest resolutions ever.… Continue Reading
For the FCPA community (and the entire human race), 2020 was a You’ve-Got-to-be-Kidding-Me year. But for our top stories, let’s jump past the pandemic and straight to the FCPA, and more specifically to three aspects of enforcement — the Good, the Bad, and the Missing.… 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
As part of Goldman Sachs’ record-breaking $3.3 billion FCPA resolution, the SEC ordered the company to disgorge $606.3 million. That’s the second biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
With Goldman Sachs’ $3.3 billion settlement, we see the failure of a sophisticated and influential financial institution to maintain strong internal controls. How did it happen? Here are the five biggest takeaways every company in any industry can benefit from.… Continue Reading
