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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

The SEC is on an ‘internal controls rampage’ when it comes to third-party relationships

Over the last two years, the Securities and Exchange Commission has set its sights on distributor and reseller relationships, and excoriated companies that failed to adequately manage and supervise them. The focus on these third-party relationships is part of the agency’s broader application of the FCPA’s internal controls provision in an increasingly aggressive manner.… 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

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