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
Beginning in 2008, when Siemens resolved its mega-FCPA case for $800 million, December has been a month of FCPA fireworks.… Continue Reading
In the prior post, I described recent FCPA enforcement actions — involving Stryker, Polycom, Microsoft, and Juniper Networks — which show that the SEC is on an ‘internal controls rampage’ involving the way issuers (public companies) establish and manage relationships with third parties, particularly distributors and resellers.… Continue Reading
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
Two very different groups of companies will emerge from the lockdown: thousands with liquidity problems and uncertain futures, and hundreds with piles of cash and an appetite for growth. That means there’s a coming surge in mergers and acquisitions.… Continue Reading
American communication technology provider Polycom Inc. settled FCPA books and records and internal accounting controls provisions charges with the SEC Wednesday for using resellers and distributors in China to bribe government officials. … Continue Reading
