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FCPA Blog Daily News

Entries in FCPA Guidance (80)


Michaela Ahlberg on Telia: Fighting corruption from the inside

Former Telia Compliance Chief Michaela AhlbergMichaela Ahlberg created a compliance program from scratch when she was hired in 2013 by Swedish telecommunications firm Telia following allegations of corruption in its foreign business dealings.

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Are there ‘aggravating circumstances’ in all FCPA cases?

The FCPA guidance that became part of the U.S. Attorneys’ Manual in November creates a presumption of declination if companies do four things -- voluntarily self-disclose, fully cooperate, properly remediate, and disgorge their profits. But there's an important exception.

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Kevin Bogdanov: How automation will shape FCPA compliance in 2018

2017 proved to be a blockbuster year for the FCPA and anti-bribery and corruption (ABC) enforcement at large.

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Sandra Orihuela: Amid Odebrecht fallout, Peru enacts world-class anti-bribery law

Peru welcomed the new year by enacting into force Law 30424, which introduces corporate criminal liability applicable to bribery.

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The three most important FCPA stories of 2017

There was plenty to ponder when looking for the biggest FCPA stories from last year. The flurry of enforcement actions in January before the transition in Washington to a new Administration. Suspense about whether the new crew would enforce the FCPA at all? Then some startling new mega-cases that reshuffled the Top Ten list.

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Andy Spalding: But what can I do before a violation occurs?

By almost any measure, the new FCPA enforcement policy is an important and positive development. Tom Fox, Bill Steinman, George Terwilliger, and others both here and beyond have noted as much, and I rise in concurrence.

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George J. Terwilliger III: Finally, A Sensible Anti-Corruption Enforcement Policy

Deputy Attorney General Rod Rosenstein’s announcement of a permanent expansion of the Department of Justice Foreign Corrupt Practices Act “Pilot Program” is good news for companies that repeatedly faced the dilemma of whether or not to investigate and disclose FCPA issues discovered internally.

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Bill Steinman: What's new about the DOJ's new FCPA corporate enforcement policy?

FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. In the words of one of my colleagues, the audience “noticeably lightened up” at the Deputy AG’s news. 

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Resource Alert: Chinese translation of 2017 DOJ Fraud Section guidance

Covington & Burling has translated the February 2017 Fraud Section guidance on compliance programs into Chinese.

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Is the SEC targeting foreign companies? 

Charles Cain, chief of the SEC's FCPA unitThe SEC has a new chief to enforce the FCPA. His name is Charles Cain. And what's important to him is leveling the playing field.

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Andy Spalding: A plea to the DOJ -- bring back pre-existing compliance

At a recent conference, I had the good fortune of asking a former high-ranking DOJ official, “how is it that pre-existing compliance is no part of the Pilot Program’s penalty reductions and declinations?”

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Andy Spalding: The Pilot Program’s missing piece

I’ve argued in prior posts that above all else, the Pilot Program is our FCPA declination policy. We’ve been asking for this now for years, and thus it is an important step. But still, something is missing. Let’s figure that out.

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