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

FCPA Blog Daily News

Entries in FCPA Guidance (86)


Yes, ‘ethical culture’ can be measured

When the U.S. Department of Justice recently updated its “Evaluation of Corporate Compliance Programs,” the enforcement agency unambiguously underlined how important it is for a company to create and foster a culture of ethics and compliance. But how does a company measure its culture of compliance, and what steps does it take in response to its measurement of the compliance culture?

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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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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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Resource Alert: Chinese translation of new DOJ guidance for evaluating compliance programs

Covington & Burling has translated into Chinese the DOJ's April 2019 Guidance Document for the Evaluation of Corporate Compliance Programs.

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Brackett and Earley: DOJ enforcement policy announcements provide promising guidance

In a series of key policy announcements between November 2017 and May 2018, the Department of Justice has demonstrated an increasingly coherent perspective on how it will handle key aspects of white collar criminal enforcement.

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Compliance is there to protect workers, not punish them

Tomorrow is May 1st -- also known as May Day or International Workers' Day -- a public holiday in most of the world, including our present location. It's a day to honor workers and their achievements, and to give people a well-timed spring holiday.

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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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