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
Switzerland-based mining and commodities giant Glencore plc landed on the FCPA Blog’s top ten last year when it paid $700 million to settle widespread FCPA offenses. How does its anti-corruption and bribery policy compare?… Continue Reading
At the gatehouse, the security guard passed me a Novartis visitor’s badge, and I turned to walk down Fabrikstrasse – the campus’ central boulevard. Two thoughts popped into my head: I think I’m too early (I was) and I hope these people are friendly (they were).… Continue Reading
The lone exception written into the FCPA allows bribes for “routine governmental action . . . which is ordinarily and commonly performed by a foreign official.” That sounds simple, but it’s not.… Continue Reading
So far this year, two FCPA enforcement actions have involved companies that resolved previous FCPA violations. With Tenaris in June, and Oracle this week, the number of FCPA recidivists rises to 15.… Continue Reading
Kraft Heinz produces some of the world’s favorite foods that have been pantry staples for generations. Every person reading this post is almost certain to have at least one Kraft Heinz product in their kitchen.… Continue Reading
The London-based luxury brand is highly-regarded for its stylish clothes and cheerful bags. Founded in 1856, Burberry has become one of the most sought after high-end retailers in the world. How sweet is the aroma of its anti-bribery and corruption policy?… Continue Reading
We have benchmarked fifteen anti-bribery policies from some of the world’s largest and best-known companies that cover an estimated 4.2 million employees. With an unexpected amount of variety among the policies, here are some interesting things we’ve learned.… Continue Reading
Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading
The Texas-based oil and gas giant employs over 65,000 people and has refineries in 21 countries. At 18 pages, ExxonMobil’s anti-bribery policy is the second longest we’ve seen behind VW’s 36-page policy.… Continue Reading
London-based consumer goods conglomerate Unilever employs around 150,000 people worldwide. It has over 400 brands, including Dove, Hellmann’s, Axe, Knorr, and Vaseline, and its employee anti-bribery policy is a single page.… Continue Reading
The New York-headquartered biopharmaceutical giant paid the DOJ and SEC $60 million in 2012 to settle FCPA offenses in Bulgaria, Croatia, China, Czech Republic, Italy, Kazakhstan, Russia, Serbia, Indonesia, Pakistan, and Saudi Arabia.… 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
