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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

FCPA enforcement report for Q3 2019

During the third calendar quarter there were seven corporate FCPA enforcement actions with penalties and disgorgement totaling about $78.5 million.

For comparison, in Q3 2018 there were also seven corporate FCPA enforcement actions.… Continue Reading

Juniper Networks lands DOJ declination

Juniper Networks, Inc. said an SEC filing Friday that the DOJ has closed its FCPA investigation of the company and won’t bring an enforcement action.

The SEC’s investigation is still pending, Juniper said.… Continue Reading

Juniper’s 52 words

Juniper Networks, Inc. Thursday revealed a previously undisclosed FCPA investigation by the DOJ and SEC.

Its Form 10-Q filed with the SEC used just 52 words to break the news, one of the shortest FCPA disclosures on record.… Continue Reading