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Editors

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

Posts Tagged: Top Ten

Is your ‘business rationale’ for intermediaries fact or fiction?

Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading

Country count for the top ten list

The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading

State-Granted Monopolies: Are they your best (and worst) customers?

They are so familiar to those of us who follow FCPA enforcement actions that we’re likely to stop noticing them. Petrobras in Brazil, Corpoelec and PDVSA in Venezuela, Pemex and CFE in Mexico, Takilant in Uzbekistan, Sonangol in Angola, Alba in Bahrain, Telecommunications D’Haiti, 1MDB in Malaysia, and Pertamina in Indonesia.… Continue Reading

Is an ‘industry sweep’ headed your way?

It’s a familiar FCPA enforcement pattern. Companies in the same segment fall like dominoes. Medical device makers, pharmas, banks, mobile phone operators, oil and gas service providers and producers — all have had their turn in the enforcement spotlight.… Continue Reading

The 2020 FCPA Enforcement Index

In 2020, the DOJ and SEC brought FCPA enforcement actions against 12 companies and imposed financial penalties totaling a record $6.4 billion. For a comparison, in 2019, 14 companies paid a (then) record $2.9 billion to resolve FCPA cases.… Continue Reading

At Large: Did ‘culture shock’ derail Beam Suntory’s criminal FCPA resolution?

How to explain it? Beam Suntory’s 2018 FCPA civil settlement with the SEC went so well. The SEC praised the company’s cooperation and took into account its good behavior. And yet in 2020, when Beam Suntory finally resolved criminal FCPA charges, the DOJ brought faint praise and heavy criticism, citing the company’s “inconsistent and, at times, inadequate cooperation,” among other transgressions.… Continue Reading