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
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
The DOJ and SEC have prosecuted 240 different companies (by my count) for FCPA offenses. Of those 240 companies, 13 have been repeat FCPA defendants. That means the recidivism rate for all corporate FCPA defendants is about 5.5 percent.… Continue Reading
The Coca-Cola Company, incorporated in 1892, is one of the world’s oldest, most well-known, and widely consumed brands. How does it’s anti-bribery policy compare?… Continue Reading
In June 2019, Walmart paid the DOJ and SEC $282 million to settle allegations that it violated the FCPA by paying an intermediary in Brazil for help obtaining construction permits and having weak anti-corruption internal controls in Brazil, China, India, and Mexico.… Continue Reading
In January 2020, Airbus SE paid $4 billion to settle global bribery and trade charges with French, UK, and U.S. authorities after an eight-year investigation. How does its anti-corruption policy compare?… Continue Reading
Recently, the FCPA Blog featured the Novartis anti-bribery policy as part of its respective benchmark series. The design and implementation of an effective anti-bribery policy is undoubtedly one of the pillars of every serious compliance program — but it should not be seen as the only one.… Continue Reading
Microsoft has one of the most interesting anti-corruption policies we’ve reviewed and the only one to cover two rarely acknowledged topics: extortion and threats. … Continue Reading
Here’s a strange fact. Some corporate anti-bribery policies give no reason for employees not to pay bribes. Or rather, the only reason they give is that the company doesn’t allow or tolerate bribery.… Continue Reading
Novartis updated its anti-bribery policy four months after the Swiss pharma paid $346.7 million to resolve FCPA offenses in Greece, Vietnam, and South Korea. Here are some interesting details from the latest version.… Continue Reading
As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.… Continue Reading
There have been a dozen corporate FCPA enforcement actions this year, including two of the biggest resolutions ever.… Continue Reading
Last month, the Commodity Futures Trading Commission ordered JPMorgan Chase & Company and its subsidiaries to pay a total of $920.2 million for artificially manipulating market prices of precious metals by sending false signals to other market participants.… Continue Reading
