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

Entries in Caremark (6)


Mike Scher: Federal healthcare guidance already demands Compliance 2.0 standards

During the past month, I've been in London at the SCCE European initiative conference and last week at the Florida convention of the Health Care Compliance Association. The month has been an opportunity to gain some new perspective on the community of global compliance officers.

Click to read more ...


Mapping the World of ‘Compliance Checking’

Official expectations that companies will check to make sure that their compliance and ethics (“C&E”) standards are being followed have existed since the advent of the Federal Sentencing Guidelines for Organizations in 1991. Additionally, only a year later, a U.S. Department of Justice official emphasized the importance of auditing to antitrust compliance, which underscored that checking was expected not only regarding the overall compliance program (e.g., training, the hotline) but also substantive areas of risk. However, while checking expectations have been present from the beginning of the “Age of Compliance,” for many reasons they are more significant now than ever before.

Click to read more ...


Dispatch from the SCCE Compliance & Ethics Institute (Part Five, conclusion)

The SCCE Compliance & Ethics Institute could become the focus for an annual debate within the compliance field about the critical issues ahead. In honor of the SCCE’s 10 years of supporting compliance officers, here are my top ten suggestions for next year’s SCCE agenda:

Click to read more ...


Walmart in Delaware: A tale of red flags ignored

At oral argument Thursday in the Delaware Supreme Court, where Walmart is appealing a lower court order to produce internal FCPA investigation files to shareholders, one remarkable exchange indicated that the idea of revising the Caremark standards, which I talked about in my prior post, was squarely on the minds of the justices.

Click to read more ...


Parental controls: Anti-corruption compliance programs for joint ventures, subsidiaries and franchisees (Part 2)

In this second post of an eight-part series on "parental controls" (Part 1 is here), we explore the types of harm that parent companies may suffer for the wrongdoing that occurs at joint ventures, subsidiaries and franchisees.

Click to read more ...


Gold dust for compliance officers

What's the first thing compliance officers need to do? We'd say it's convincing management and board members they need an effective compliance program. That's not easy. It takes advocacy, and advocacy takes credibility.

Click to read more ...