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
The Justice Department Thursday charged two former Herbalife executives with bribing Chinese officials for ten years and covering it up by lying to the SEC and destroying evidence.… Continue Reading
The name sounds objective and exact — even scientific. The internal controls provisions. But in real life, how do internal controls measure up? Do they work?
To review — the FCPA requires issuers to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that all transactions are properly executed and recorded and all assets are accounted for.… Continue Reading
Nearly every corporate anti-bribery violation reveals problems with internal controls.
Again and again SEC enforcement actions describe devious employees who were able to subvert the controls and thereby create slush funds and pay bribes, or controls that were weak to begin with and incapable of detecting or stopping the corrupt actors.… Continue Reading