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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

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: Intermediaries

Is your ‘business rationale’ for intermediaries fact or fiction?

Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading

Don’t expect agents to keep quiet about bribes they pay

In nearly all FCPA enforcement actions, agents, consultants, suppliers, distributors, and partners — whether real or faux — have a hand in bribery. They make approaches to foreign officials, set up offshore shell companies, generate fake invoices, and move money through accounts they own or control.… Continue Reading

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