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 Effective Compliance Program (124)


John Bray: Can companies really adopt a single global anti-corruption policy?

How far is it feasible to apply a global compliance policy in widely differing regional markets? And to what extent should there be local policy exceptions?

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Is corporate bribery more like a car accident or an airplane crash?

Nearly 100 percent of the FCPA Blog's readers have experienced traveling in a car when it broke down. But how many have experienced a commercial airplane breakdown while in flight? Almost zero percent.

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Bethany Hipp: Experienced compliance professionals are a good investment

In the frenzy of upsizing, downsizing and rightsizing compliance programs after downturns in the market or in the midst or aftermath of a major investigation, it’s important to keep in mind that experienced lawyers and compliance professionals bring significant value to a company.

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Randy Stephens: Questions prosecutors ask about compliance programs

The Justice Department's new guidance about how it will evaluate corporate compliance programs takes the form of questions its prosecutors would typically ask about a corporate compliance program during an investigation.

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Julie DiMauro: Best practices for today's CCO

Let's start this discussion with: Know the business.

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The DOJ Pilot Program: Financial considerations for both companies and their executives

The DOJ Fraud Section’s recently released FCPA Enforcement Plan and Guidance outlines a novel one-year pilot program for corporate self-reporting and cooperation, with specific fine reduction incentives.

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DOJ launches FCPA self-reporting pilot program with new guidance

Assistant Attorney General Leslie R. CaldwellAssistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.

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Brooke Hopkins: But is your compliance program scalable? 

The DOJ and SEC haven't used the word "scalable" to describe an effective compliance program. But they've described scalability when talking about what's needed.

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Mike Scher: Compliance officers are executives and subject matter experts

It was a relief to read in a recent post on the FCPA Blog that compliance officers aren't crazy, but are in a tough job, always caught between flawed human nature and meeting the ideals of effective management and business integrity.

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Are compliance officers crazy?

The verdict of history is unanimous: human beings can find trouble anywhere, and always do. We're geniuses when it comes to messing things up.

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How to hire a princeling: Six rules anyone can follow

Last week BNY Mellon agreed to pay the SEC $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act by awarding student internships to kids of officials connected with a sovereign wealth fund in the Middle East.

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Mike Scher: Scapegoats are out, compliance badasses are in

It's time for the compliance community to be hopeful. In the same month, the DOJ announced it was hiring a compliance expert to help make charging decisions, and an administrative law judge refused to allow the SEC to sanction a former Wells Fargo Advisors compliance officer because doing so would make her a scapegoat.

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