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
Earlier this month, telecom giant Ericsson agreed to resolve breaches of its 2019 FCPA DPA by paying $206.7 million in new penalties and pleading guilty to charges deferred by the DPA — one count of conspiracy to violate the FCPA anti-bribery provisions and one count of conspiracy to violate the internal controls and books and records provisions.… Continue Reading
Last month, French firm Safran S.A. received the DOJ’s 16th declination with disgorgement. Remember how declinations with disgorgement came into being?… Continue Reading
French aerospace defense company Safran S.A. received a declination from the DOJ last week despite bribery that violated the FCPA.… Continue Reading
When the DOJ and SEC published their FCPA Resource Guide, they emphasized the connection between remedial action and enforcement. The Guide makes clear that no company can expect a favorable FCPA resolution unless it takes adequate remedial action, and conversely, companies that fail to do that are more likely to face charges and harsher FCPA penalties.… Continue Reading
What can a company do to convince prosecutors, regulators, and sentencing judges that it is committed to compliance? The question needs an answer because commitment is the feds’ threshold issue and the top-ranked hallmark when evaluating compliance programs.… Continue Reading
The Evaluation of Corporate Compliance Programs, first published five years ago, is now one of the most important compliance tools, not only for the DOJ prosecutors it’s addressed to, but also for compliance professionals outside government.… Continue Reading
One of the least understood aspects of anti-corruption compliance outside the compliance community is that perfection isn’t required. Compliance involves people, and whenever people are involved, things get messy. Compliance professionals know it and so do the feds.… Continue Reading
A lot of credit for equating managing with math goes to the late Peter Drucker, pictured left. “What gets measured gets managed,” he said, and “If you can’t measure it, you can’t improve it.”… Continue Reading
Have you noticed how many corporate FCPA enforcement actions recount old facts. Really old facts — sometimes from more than a decade ago. Why should we care about all that ancient history?… Continue Reading
They craft policies, train employees, oversee due diligence, perform risk assessments, and lead investigations. But there’s another compliance role that’s practically unknown: disciplinarian. … Continue Reading
Every compliance training session should include this warning: If you ever become involved with, see, or otherwise discover a potential FCPA violation, stop everything. Don’t clean your desk, empty the trash can, or clear your browser history.… Continue Reading
Why is cooperation in corporate enforcement actions such a big deal? Because from the outside, most companies are a black box. Without help, it’s impossible to know what happens inside.… Continue Reading