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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

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Feds close five-year FCPA probe of IBM

IBM said in an SEC filing that the DOJ and SEC have closed their FCPA investigations into transactions in Argentina, Bangladesh, Poland, and Ukraine.

The U.S. investigations started in early 2012 when IBM notified the SEC of a probe by the Polish Central Anti-Corruption Bureau.… Continue Reading

Enforcement Report for Q3 ‘13

DOJ and SEC enforcement of the FCPA slowed a bit during the summer months. But after a blockbuster Q2, the third quarter still saw four guilty pleas, one more than the prior quarter, and three declinations, up from two in the previous three months.… Continue Reading

Corruption Risks — China Travel Edition (Part I)

In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading

IBM discloses broad new DOJ investigation

IBM said in an SEC filing this week that the DOJ has opened an FCPA investigation into transactions in Poland, Argentina, Bangladesh, and Ukraine. ‘The DOJ is also seeking information regarding the company’s global FCPA compliance program and its public sector business,’ IBM said.… Continue Reading

Judge Leon rejects SEC, IBM settlement

A federal judge Thursday angrily rejected a proposed 2011 settlement between the SEC and IBM, saying the  company should be required to report all accounting violations and not just FCPA anti-bribery problems.… Continue Reading