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
For three enterprising professors from Georgetown University, the early days of Covid-19 — before the vaccines, when none of us knew what to do outside our homes — created a pristine environment to study how people perceive and handle risk.… 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
In a previous post on the FCPA Blog I briefly explored five ways to make the most of risk assessments. Since then, interest in risk assessment has continued to be very strong.… Continue Reading
One of the byproducts of our locked-down, socially distanced, mask-wearing, remote-working world is that introverts are feeling more comfortable. They don’t need to pretend to be part of the gregarious, fist-bumping, loud-talking in-crowd of corporate extroverts, and that’s a big relief.… Continue Reading
When the first set of general corporate compliance program standards – the Federal Sentencing Guidelines for Organizations – was issued in 1991, there was no mention of risk assessment. More recent standards, however – including the “Evaluation of Corporate Compliance Programs” issued by the U.S.… Continue Reading
Behavioral ethics is a well-known field of social science which shows how — due to various cognitive biases — “we are not as ethical as we think.” Behavioral compliance and ethics (which is less well known) attempts to use behavioral ethics insights to develop and maintain effective compliance programs.… Continue Reading
With a rise in global trade and a focus on international development, the past two decades have seen increased attention to the worldwide problem of corruption. With that attention have come efforts to measure the degree of corruption from one country to another.… Continue Reading
Nearly 100 percent of the FCPA Blog’s readers have experienced traveling in a car when it broke down. But how many have experienced a commercial airplane breakdown while in flight? Almost zero percent.… Continue Reading
Last week I came across a gem of a post over on ACL’s in-house blog, about the future of internal audit. One of the senior executives there, Dan Zitting, was talking about the premium that recruiters now place on audit executives who understand data analytics — to the extreme that one recruiter told Zitting, “Frankly no one in management truly needs the services of the traditional auditor any more; what they need is the promise of Big Data to materialize.”… Continue Reading
We wrote an e-book as a guide to navigating corruption challenges in emerging markets.
As practitioners and compliance officers know, there is no one-size-fits-all compliance program that a company can simply adopt or pull off the shelf. … Continue Reading
Consistent with the DOJ’s Opinion Release 08-02, companies must risk-rank their third parties into high, medium and low risk categories and conduct the appropriate due diligence.
As 85-90% of all cases involve illegal activity conducted by a third party on behalf of an organization, this issue appears to be the biggest risk to multinational organizations.… Continue Reading
In this fourth of eight installments, we look at risk assessments and mitigation measures for joint venture (JV) interests. You can find Parts One, Two, and Three here.
Risk assessments are an important tool for JVs to understand their compliance risks better and for parent companies to monitor those risks and mitigation measures.… Continue Reading