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
Wal-Mart announced it has now spent over $300 million on FCPA compliance costs. Some FCPA watchers are so indignant by the $300 million figure they have broken it down into FCPA compliance dollars spent per day, while others imply it’s an impressive show of compliance remorse.… Continue Reading
The proceeds of FCPA enforcement actions currently go directly into the U.S. Treasury. But that need not be so. My proposed Supplemental Transparency Project would use a portion of the settlement proceeds to directly fund programs in the countries where the bribery occurred.… Continue Reading
I suggested in the last post that using the proceeds of an FCPA enforcement action to directly compensate overseas victims had been done before. And it really worked. Or I should say, it is still working, to this day.… Continue Reading
We saw in the last post that neither restitution nor disgorgement will work very well in compensating the victims of overseas corporate bribery.
But here’s something that might.
Look at what the federal enforcement agencies already do in the field of environmental law.… Continue Reading