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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

Why do ‘normal’ employees violate the FCPA?

People who’ve violated the Foreign Corrupt Practices Act fall into two categories: those who had criminal intent from the start, and those who stumbled into the offense.

It’s the second group — the regular folks who’ve done a bad thing — who are so tragic.… Continue Reading

ISO 37001 is here. Will It Work?

On October 14, after four years of work involving the active participation of experts from 37 countries, the International Organization for Standardization issued ISO 3700, its standard for anti-bribery management systems.… Continue Reading

Worth MacMurray: The DOJ is emphasizing a ‘culture of compliance’

Leslie R. Caldwell, Assistant Attorney General for the Criminal DivisionThe DOJ’s FCPA Guidance and Enforcement Plan places significant emphasis on organizational culture. The section describing “an effective compliance and ethics program” includes “whether the company has established a culture of compliance, including an awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”… Continue Reading

Billy Jacobson on the New FCPA Guidance: DOJ swings and misses

On April 5 the DOJ’s Fraud Section of the Criminal Division released a policy document called The Fraud Sections’ Foreign Corrupt Practices Act Enforcement Plan and Guidance. The new Guidance is an attempt to bring greater transparency to the benefits corporations will achieve by voluntarily disclosing FCPA problems and fully cooperating with investigations of these problems. … Continue Reading