Search

Editors

Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

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 FCPA Guidance (67)

Thursday
Aug102017

Jampol and Aibel: DOJ targets healthcare with FCPA enforcement

The acting chief of the DOJ's Criminal Fraud Section announced a new partnership last month between the DOJ’s Healthcare Fraud Unit’s Corporate Strike Force and Foreign Corrupt Practices Act prosecutors.

Click to read more ...

Thursday
May042017

Karen E. Gray: A plan for risk-based monitoring is essential

The award-winning films "Spotlight" and "All the President’s Men" both chronicled investigative journalism that uncovered huge scandals. But in re-watching those movies, I've noticed something else they have in common -- journalists who kept following the bread crumbs.

Click to read more ...

Wednesday
Apr052017

Azish Filabi: Is your legal department creating organizational risk?

At the 2017 Global Ethics Summit, put on by the Ethisphere Institute, Caroline Rees of SHIFT spoke on a panel about business and human rights.

Click to read more ...

Tuesday
Feb282017

Michele Edwards: Data analysis underlies new DOJ guidance

The Justice Department's “Evaluation of Corporate Compliance Programs” outlines 11 topics and 119 questions that the Fraud Section commonly considers when evaluating corporate compliance programs in the wake of criminal misconduct.

Click to read more ...

Thursday
Feb232017

Tom Fox: Compliance in the Age of Mercantilism

What does the failure of the Kraft Heinz attempted hostile takeover of Unilever portend for the greater world of global anti-corruption enforcement specifically and compliance programs more generally?

Click to read more ...

Monday
Oct172016

ISO 37001 is here. Will It Work?

On October 14, after four years of work involving the active participation of experts from 37 countries, the International Organization for Standardization issued ISO 3700, its standard for anti-bribery management systems.

Click to read more ...

Tuesday
Apr262016

Paul Pelletier on the Search for Mr. Goodboss: Who Should be the Next FCPA Chief?

The recent announcement that DOJ is taking applications for the newly vacated FCPA Chief position provides a timely opportunity to reflect on the history, growth and direction of the Unit as well as a chance to consider the unique game-changing possibilities that await an accomplished selectee.

Click to read more ...

Monday
Apr182016

Worth MacMurray: The DOJ is emphasizing a ‘culture of compliance’

Leslie R. Caldwell, Assistant Attorney General for the Criminal DivisionThe DOJ’s FCPA Guidance and Enforcement Plan places significant emphasis on organizational culture. The section describing “an effective compliance and ethics program” includes “whether the company has established a culture of compliance, including an awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”

Click to read more ...

Tuesday
Apr122016

Bill Steinman: Let's talk about per diems, without the shouting

Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it. 

Click to read more ...

Thursday
Apr072016

Billy Jacobson on the New FCPA Guidance: DOJ swings and misses

On April 5 the DOJ's Fraud Section of the Criminal Division released a policy document called The Fraud Sections’ Foreign Corrupt Practices Act Enforcement Plan and Guidance. The new Guidance is an attempt to bring greater transparency to the benefits corporations will achieve by voluntarily disclosing FCPA problems and fully cooperating with investigations of these problems. 

Click to read more ...

Thursday
Apr072016

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.

Click to read more ...

Tuesday
Apr052016

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.

Click to read more ...