News and commentary about white-collar crime, enforcement, and compliance
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
Many come to The FCPA Blog seeking compliance guidelines. That’s good, because our aim is to help people comply with the U.S. Foreign Corrupt Practices Act. Some seekers, however, have noticed that our posts and resources don’t include any out-of-the-box compliance programs, at least not yet.… Continue Reading
The affirmative defense for promotional expenses has always been a riddle, which explains why it appears so often among the Justice Department’s Opinion Procedure Releases, including both Releases so far this year.… Continue Reading
In its second Opinion Procedure Release of 2007, the Department of Justice again looked at promotional expenses. An affirmative defense in the U.S. Foreign Corrupt Practices Act allows payment or reimbursement of expenses of foreign officials that are directly related to “the promotion, demonstration, or explanation of products or services.”… Continue Reading
In its first Opinion Procedure Release of 2007, the Department of Justice said it would take no action against a requestor proposing to cover some expenses for a