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FCPA Blog Daily News

Entries in FCPA Guidance (64)

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.

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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?

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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.

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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.

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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.”

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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. 

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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. 

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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.

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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.

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Monday
Mar282016

Alexandra Wrage: The pros and (substantial) cons of an ISO anti-bribery standard

The international business community wins when companies across supply and marketing chains work to the same high standards. There is less risk and more predictability, which promotes confidence among business partners. Benchmarking among peers and establishing and sharing model language and best practices all help to ensure that companies set their sights on a reasonable common denominator for compliance. 

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Monday
Mar212016

Corrupt officials are like muggers. They look for weak victims

In two prior posts (here and here), I’ve talked about how American companies can do FCPA-compliant business in Kazakhstan and other emerging markets. In this post, I’d like to provide a few more practical tips.

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Tuesday
Feb162016

Matt Kelly: Don’t forget to review and comment on ISO 37001

Corporate compliance enthusiasts have one more item on their To Do list this winter: be sure to review and comment on ISO 37001, the draft standard for anti-bribery management systems.

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