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
We have seen a rapid increase in dedicated ethics and compliance departments and programs in Nordic companies during the last decade. However, there is no local regulation that explicitly requires formal ethics and compliance work.… Continue Reading
You may have noticed a risk factor in annual reports and SEC registration statements about “conflicting laws and regulations.” Once rare, the warning has become common, thanks to globalized operations and proliferating regulators.… Continue Reading
Shearman & Sterling has published a client alert a lot of us need these days — “Transacting Business During a Corruption Investigation.”
Why an alert about doing business during an investigation?… Continue Reading
Professor Peter J. Henning of Wayne State University Law School (Photo courtesy of Wayne Law)“Over the last decade, since the passage of the Sarbanes-Oxley Act in 2002, publicly traded corporations have poured significant resources into their compliance programs to prevent wrongdoing, or to at least be an early warning system for what might become a problem.… Continue Reading
The protests of the Brazilian people have moved their Parliament to action. Late last week, after a protracted procedural history, the Brazilian Senate approved the Clean Company Act. It now goes to President Dilma Rousseff for final approval.… Continue Reading
I’ve argued in this series that freedom from bribery is a human right, and that FCPA enforcement should do more to protect those rights.
In the past two posts (here and here) we explored one mechanism under U.S.… Continue Reading
Only five years ago, no one talked about self disclosing potential FCPA violations.
Today, a mere blink of an eye later, self disclosure is the norm.
In our era of hyper-enforcement and Sarbanes-Oxley driven field certifications, the new pattern is set:
Hear from a whistleblower about sensitive payments somewhere, take a quick look for credible evidence, inform the board, launch an internal investigation, disclose it to the DOJ, and write it up in the next quarterly SEC filing.… Continue Reading
