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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

These ‘mistakes’ are behind most OFAC violations

Earlier this year the Treasury Department’s Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. It describes essential components of a sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, and training).… Continue Reading

Practice Alert: Key differences in UK Bribery Act guidance versus FCPA guidance

The U.S. Department of Justice recently published new guidance on how it will assess corporate compliance programs. The DOJ Guidance streamlines previous U.S. guidance and expands on key subjects; providing a greater insight into how the the DOJ will approach its evaluation of compliance programs when considering whether a prosecution or other resolution is appropriate.  … Continue Reading

DOJ reduces compliance role for monitors

Brian Benczkowski, Assistant Attorney General for the Criminal DivisionThe head of the Justice Department’s criminal division issued new guidance to prosecutors that’s likely to reduce the number of corporate settlements that require the hiring of compliance monitors.… Continue Reading

Rory Donaldson: TI-UK Guidance presents international best practices for anti-bribery compliance

Transparency International UK launched a new online tool this month to provide businesses with practical and in depth guidance on tackling bribery and corruption.

In producing this tool we’ve worked with over 120 leading compliance and legal experts, over the course of eight years and we’re proud to be able to offer it as a free-to-use resource for businesses.… Continue Reading

Donna Boehme: The DOJ and Hui Chen define the future of compliance

In the Justice Department’s new guidance for compliance programs, which appeared online unannounced, undated and unsigned, one detects the experienced hand of the DOJ’s new Compliance Counsel, Hui Chen.

I am so impressed by the content of the Evaluation of Corporate Compliance Programs that I suggest the DOJ rename this document: Evaluation of Corporate Compliance Programs (This Is What True Compliance Subject Matter Expertise (SME) Looks Like). … Continue Reading