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
In my previous post, I looked at the drivers behind a “behavioral revolution” now happening in banks. Diving deeper into this, let’s unpack what’s behind the “subculture audits” concept, and how these are different from and more effective than the culture assessment surveys we are all familiar with.… Continue Reading
The UN Global Compact published “A Guide for Anti-Corruption Risk Assessment” in 2013 that many companies worldwide adopted. With a further push from the DOJ and other agencies toward risk-based compliance, risk assessment models became a cornerstone of modern programs.… Continue Reading
Extending compliance programs to subcontractors has always been tricky. Interfere too much, and your company becomes liable for whatever goes wrong. A hands-off approach won’t work either. When subs flake out, prosecutors blame the head-in-the-sand attitude for the damage.… Continue Reading
Many of the recent posts on the FCPA Blog have dealt with various aspects of Covid-19: our very personal health concerns, enhanced bribery risks, enforcement, and the possible impact on the operation of compliance systems and compliance organizations in times of travel bans and budget constraints in many industries.… Continue Reading
