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Editors

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

And the big compliance story for 2019 is . . . .

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

Risk Alert: Are bribes lurking on the balance sheet?

When choosing transactions to test as part of anti-bribery assessments, the usual suspects include expense accounts like consulting, marketing, promotions, commissions, or miscellaneous. Other expense accounts are selected based on the nature of the company’s business, risk factors or descriptions of the account.… Continue Reading

David McLaughlin: How AI can nail a bribe paying scrap metal dealer

Last year 27 companies paid nearly $2.5 billion to resolve FCPA-related offenses. So far this year, 9 companies have paid more than $1.2 billion for FCPA-related settlements. Yet despite these staggering outcomes, existing tools deployed today by corporations are not capable of effectively mitigating FCPA risk.… Continue Reading

Key Energy pays $5 million to settle FCPA offenses in Mexico

Houston-based Key Energy Services, Inc. agreed to disgorge $5 million to settle Foreign Corrupt Practices Act offenses caused by bribes from its Mexican subsidiary to an employee at state-owned Pemex.

The SEC Friday charged Key Energy in an internal administrative order with violating the FCPA’s internal controls and books-and-records provisions.… Continue Reading

After Bruker: How much compliance is enough?

In the world of anti-corruption internal controls, there is no “one-size-fits-all” model. Ideally, design and implementation of such controls should be thoughtful, rigorous and based on a robust and re-performable corruption risk assessment. … Continue Reading