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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

Intermediaries: Separating red flags from red herrings

In this era of heightened FCPA enforcement, it is easy to assume that a red flag signals the end of a relationship with a business intermediary. By my count, 11 of the last 17 FCPA enforcement actions involved bribes funneled to foreign officials through third parties.… Continue Reading

Alexandra Wrage on Panasonic: Bad actors rarely work alone

At every FCPA conference, someone comments that over 90 percent of FCPA matters involve third party intermediaries. It’s an interesting statistic and can be useful if it helps motivate the team to take due diligence seriously and encourages management to fund the program.… Continue Reading

Bill Steinman: Can you trust your offset advisor?

Satisfying offset obligations is hard. Readers will recall that offsets are financial obligations imposed on defense contractors by foreign government customers as a condition to defense procurements.  

For every dollar of financial benefit the defense contractor creates in the country in question, it is given credit towards satisfying its obligation. Continue Reading

Richard Bistrong: The dangerous charm of agents

What is it about agents, fixers, and intermediaries that makes them so attractive while potentially toxic to multinationals?

If you haven’t spent extended time with them, it’s hard to understand.

So here’s what I shared last week at the FCPA Blog NYC Conference.… Continue Reading

Richard Bistrong: In defense of, ahem, intermediaries

International success now depends on business leaders having “the foreign policy acumen to distinguish what they can and cannot do,” according to John Chipman, the director-general and chief executive of the International Institute for Strategic Studies.… Continue Reading