Richard L. Cassin

My gifted colleagues — the people Harry and I leaned on for support for 17 years — have already written a wonderful history of the FCPA Blog. There’s little more I can say except to fill in a gap they left in the record — their role in what we did. To set the stage: When the FCPA Blog started in 2007, the Foreign Corrupt Practices Act was almost unknown. There wasn’t much to report and few readers. Then, at the end of 2008, Siemens happened.

It’s wishful thinking that a corporate FCPA resolution with the DOJ puts everything in the rearview mirror. Better to view corporate resolutions as multi-year events, during which the company and its leaders face more scrutiny and potential criminal jeopardy than ever. That’s because of what’s inside today’s deferred prosecution agreements. By the time the corporation lands a DPA, it has already more or less cooperated with the DOJ and remediated defects in its compliance program.

The viral video of two unprepared HR reps from Cloudflare firing Brittany Pietsch from her remote sales job is excruciating.