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Editors

Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman 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

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

Wednesday
Jul172019

World Bank debars U.S. technology company

The World Bank debarred an American technology company Wednesday for 12 months for "collusive practices" involving a national ID project in Bangladesh.

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Wednesday
Jul172019

How Walmart outgrew its compliance program

Despite well-documented missteps in Germany and South Korea, the late 2000s were a dynamic time for Walmart’s expansion efforts worldwide. Beginning with forays into Canada, Mexico and the UK in the mid-90s, by 2015 Walmart International had become an empire unto itself, operating in 26 countries and accounting for over a quarter of the retail giant’s net sales.

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Tuesday
Jul162019

Do modern Codes of Conduct help cause and conceal unethical behavior?

How well positioned are today’s code-of-conduct practices to meet the effectiveness criteria for Corporate Compliance Programs embedded in the latest DOJ guidelines? That is, "Is the compliance program well designed? Is it being implemented effectively? And does it work in practice?”

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Tuesday
Jul162019

Practice Alert: Mexico expands asset forfeiture to anti-corruption enforcement

Legislative changes in Mexico continue to expand the tools prosecutors have to fight corruption and to effectively recover illicitly acquired assets, particularly from corrupt activities. This is all the more significant given the recent major prosecutorial actions against the former CEO of PEMEX and others in what seems to indicate Mexico's turn toward pursuing major corruption cases.

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Monday
Jul152019

Job: Programme Officer ICAR

Job Title: Programme Officer ICAR

Employer: Basel Institute on Governance

Location: Basel, Switzerland

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Monday
Jul152019

UK court approves first-of-its kind ‘group’ DPA

On July 4, 2019, the UK’s fifth Deferred Prosecution Agreement was approved. The DPA is between the Serious Fraud Office and Serco Geografix Limited (SGL), a subsidiary of Serco Group PLC, and relates to fraud and false accounting offenses.

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Friday
Jul122019

Has your compliance program ‘evolved’ beyond ethics?

Though in the aggregate the increase in modern differentiation and complexity has been a boon to humankind, it is perhaps helpful (or at least practical) to view these developments as evolutionary processes without telos.

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Thursday
Jul112019

Job: General Counsel, Government Services

Job Title: General Counsel, Government Services

Employer: Day & Zimmermann

Location: Chantilly, Virginia USA

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Thursday
Jul112019

The new star of the DOJ Guidance is ‘risk’

The DOJ’s April 2019 guidance for prosecutors on compliance programs reflects a belief that even as risk taking drives business behavior, so too should legal (particularly criminal) risk drive and inform a business’s compliance program. Simply stated, the more significant the risk-taking environment, the greater the chances for criminal behavior.

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Wednesday
Jul102019

FCPA defendants need an ‘adequate procedures’ defense, too

The Department of Justice recently updated and published its guidelines for evaluating corporate compliance programs in the FCPA context. The Guidelines are remarkably thorough, but the text is aimed principally at assisting prosecutors with charging decisions, setting sanction amounts, and crafting subsequent compliance obligations -- rather than at the corporate entities that are expected to phase in those compliance programs.

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Wednesday
Jul102019

D&O Liability Insurance: Hazards for the CCO

Legal claims are regularly brought against corporate officials through a wide variety of angles, including, for example, allegations of breach of fiduciary duty and willful disregard of regulatory imperatives, or for a range of statutory violations premised in financial crimes, like bribery or insider trading.

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Tuesday
Jul092019

Here’s my advice, from the heart, to any FCPA defendant

Not all FBI stings in FCPA cases are alike. That became clear in the prosecution of Roger Richard Boncy and Joseph Baptiste. They were found guilty of FCPA and related offenses last month after a two-week jury trial in which the DOJ said they solicited “bribes from undercover agents posing as potential investors in a proposed port development project in the Mȏle St. Nicolas area of Haiti.”

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