News and commentary about white-collar crime, enforcement, and compliance
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
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.… Continue Reading
I see it time and time again — third parties that would otherwise pass muster under a client’s due diligence process create their own red flags.
They push back on a local registration requirement.… Continue Reading
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
Working with third parties continues to be the single biggest corruption risk for business. Almost one in two enforcement actions concluded since the OECD Anti-Bribery Convention came into force in 1999 was the result of bribery through sales agents, intermediaries, distributors or brokers.… Continue Reading
This week I’m traveling to the Middle East for the first time in ten years. It’s a welcome return to a region where I spent a lot of time, and where I enjoyed dealing with agents and end users.… Continue Reading
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.… Continue Reading
When was the last time you did a third-party program check-up? Not a full review of all your third parties but something you can perform on a quarterly, semi-annual or annual basis with desktop tools available to you or your compliance team.… Continue Reading
There is a long-standing debate over the benefits and drawbacks of using intermediaries to generate and retain business.
Numerous FCPA Blog posts have explained how agents and intermediaries can provide vital support to companies looking to break into foreign markets.
At the same time, intermediaries may expose companies using them to significant risk by engaging in fraud or corrupt practices, with or without the principal’s knowledge.… Continue Reading
Writing in The Guardian, the paper’s financial editor Nils Pratley recently summed up £671 million ($800 million) in fines meted out to Rolls-Royce, in the aftermath of the various corruption investigations, as “big, ugly and serious.”
Pratley’s four-word summary sounds like a title for a Hollywood blockbuster.… Continue Reading
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.… Continue Reading
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
A Gabonese national who was allegedly paid $3.5 million for facilitation services in Africa by hedge fund Och-Ziff was arrested this week as part of an FCPA investigation.… Continue Reading