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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

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: travel and entertainment expenses

Hitting the highpoints with the DOJ

Gifts, travel and entertainment, foreign officials, successor liability, and effective compliance programs.

They’re among the topics covered by the new 120-page joint DOJ and SEC guidance on the FCPA.

In the fact sheet accompanying the guidance, the DOJ summarized its position on those topics.… Continue Reading

What’s really inside the new guidance?

Just over a year after Assistant Attorney General Lanny A. Breuer first announced plans to issue “detailed new guidance on the [FCPA’s] criminal and civil enforcement provisions,” the Department of Justice (“DOJ”) and the U.S.… Continue Reading

DOJ and SEC release ‘unprecedented’ joint FCPA guidance

The DOJ and SEC today released a 120-page FCPA resource guide.

It’s available in pdf here.

The foreword, signed today by the DOJ’s Lanny Breuer and the SEC’s Robert Khuzami, says:

The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.

Continue Reading

Avon keeps no secrets from the feds

In its disclosure yesterday, Avon provided a glimpse into what it means to be cooperating with the DOJ and SEC.

Avon is deep into a huge global investigation about FCPA compliance that so far has cost the company more than $280 million.… Continue Reading

Avon’s latest FCPA disclosure

From Avon Products Inc’s Form 10-Q filed with the SEC on August 1, 2012:

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As previously reported, we have engaged outside counsel to conduct an internal investigation and compliance reviews focused on compliance with the Foreign Corrupt Practices Act (‘FCPA’) and related U.S.… Continue Reading