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
In the past couple of months, sanction list screening has become one of the most critical compliance tasks. A single question has triggered much of the change: “Are my business partners and other third parties I deal with really sanctioned?”… Continue Reading
As the recent high-level and healthy debate on the FCPA Blog has shown, there are various ways to gather and analyze corruption-risk data at the country level, all of which have respective pros and cons but nevertheless are indispensable in our era of risk-based compliance decision-making.… Continue Reading
One way to understand the virulence of corruption is to look at what happens to journalists who expose it.… Continue Reading
Two compliance-related facts have emerged since the start of 2021, and they must be related. First, the DOJ’s enforcement priority has shifted to individuals who commit white-collar “corporate” crimes and away from the corporations themselves.… Continue Reading
When Russia began its invasion of Ukraine in February, four issuers had disclosed ongoing FCPA-related investigations that involved alleged conduct in Ukraine. Three of the companies are based in the United States and one in India.… Continue Reading
On April 14, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued advisory FIN-2022-A001 on Kleptocracy and Foreign Public Corruption urging financial institutions “to focus efforts on detecting the proceeds of foreign public corruption, a priority for the U.S.… Continue Reading
Formula One is an exciting spectacle. Unfathomable speed, exotic locations, and ultra-luxury brands make for a compelling fan experience without mentioning all the behind-the-scenes drama. F1 enthusiasts worldwide come together each race day to cheer on their drivers and teams.… Continue Reading
During the past two years, fear of infection and death, and shutting offices and everywhere else people meet, produced what amounts to a second pandemic: depression. While risks from Covid-19-related disruptions now appear in nearly all SEC registration statements and periodic filings, companies aren’t mentioning risks they face from employee depression.… Continue Reading
Sanctions are having a moment. The word has become synonymous with the war in Ukraine, and the complex legal mechanism has entered the mainstream vernacular. Compliance professionals need a nuanced understanding of international laws and regulations.… Continue Reading
Transparency International and over 100 other organizations released an open letter calling on governments to open up company and beneficial ownership registers as a matter of urgency, to assist in the implementation of sanctions against Russian oligarchs.… Continue Reading
On February 25, the Committee of Ministers of the Council of Europe (CoE) launched a procedure to suspend Russia from its rights of representation in the organization. Following that, on March 15, Russia informed the Secretary General of the CoE of its withdrawal from the organization and its intention to denounce the European Convention on Human Rights.… Continue Reading
We published two previous posts, the first discussing potential scenarios that Swiss individuals and entities, including foreign subsidiaries located in Switzerland, could be facing should new sanctions target certain Russian Federation individuals and entities, and the second focusing on the amendments to the Ordinance instituting measures in connection with the situation in Ukraine taking effect on February 28, 2022 (the “Original Ordinance”).… Continue Reading