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

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

DOJ publishes ‘Evaluation of Corporate Compliance Programs’

Dear FCPA Blog,
 
I am writing today because I recently learned about the DOJ’s new “Evaluation of Corporate Compliance Programs,” which they released on February 8, 2017 without apparent fanfare. 

I didn’t see this covered on the FCPA Blog (or anywhere else for that matter) and thought I would bring it to your attention (in case you, like me, had missed it). 

While it doesn’t exactly break new ground, I think it does give us an insight into Hui Chen’s views on compliance programs, and thus the DOJ’s position on the same.… Continue Reading