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 (74)

Monday
Dec042017

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.

Click to read more ...

Friday
Dec012017

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. 

Click to read more ...

Tuesday
Nov142017

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.

Click to read more ...

Monday
Nov062017

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.

Click to read more ...

Monday
Sep252017

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?”

Click to read more ...

Monday
Sep182017

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.

Click to read more ...

Tuesday
Sep052017

Worth MacMurray: A front end ISO 37001 certification audit sure beats a back end DOJ investigation

Is my anti-corruption program effective or not effective? In the United States, companies only receive the definitive answer to that question in worst case scenarios -- at the back end of a governmental program evaluation, typically while under FCPA scrutiny by the DOJ.

Click to read more ...

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 ...