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Can one really track the FCPA?

  • Writer: Richard Bistrong
    Richard Bistrong
  • May 8, 2017
  • 3 min read

Updated: Aug 17, 2021

The following Q & A is with Harry Cassin, CEO, Recathlon LLC, the parent company of the FCPA Blog.

RB: Hi Harry, first, a little about you. How did you get to the FCPA world?

HC: My father is the founder and editor-in-chief of the FCPA Blog. We’ve worked together for 10 years. I’ve had an incredible opportunity to see the changes in the compliance community and the FCPA landscape during that time. It’s a really exciting place to be.

RB:  What is FCPA Tracker?

HC: FCPA Tracker scans for and analyzes public disclosures by companies about FCPA-related investigations. Where available, our analysts pull out over 20 unique fields for each investigation that our users can use to crosscheck against other investigations.

RB: Who owns FCPA Tracker?

HC: FCPA Tracker is owned by Recathlon LLC, it’s a publishing company that also owns the FCPA Blog, and other publications.

RB: Why did you start FCPA Tracker?

HC: FCPA Tracker was initially developed as an internal research tool built to the specifications of the FCPA Blog staff for very specific research purposes. As the product developed and grew, we offered it to a few key organizations who had expressed previous interest in accessing the data now contained in FCPA Tracker.

RB: When did you launch FCPA Tracker?

HC: These initial users were really impressed with the product and found a tremendous amount of value in it within their organizations. After hearing this positive feedback, we began to roll out FCPA Tracker to the public in early April.

RB: What do people use FCPA Tracker for?

HC: This is something that has surprised us. We developed FCPA Tracker with a specific use in mind, but our clients approach the same data set with different uses in mind. People have told us they use it for research, for internal company due diligence, for client monitoring, business development, and so on.

RB: Who uses FCPA Tracker?

HC: Due to the nature of the content, we don’t disclose any information about our current corporate or government users.

RB: Who is a typical user of FCPA Tracker?

HC: Our typical user is part of an enterprise team at a Fortune 500. We do have individual and government licenses, but the average user of FCPA Tracker is a team of people.

RB: Do you have trial periods?

HC: We’ve made public a single active company from the FCPA Tracker system. We also have public pages that detail what FCPA Tracker is, and the information that’s published. None of our users have needed training on how to use FCPA Tracker. It’s extremely intuitive and easy to use.

RB: Who are FCPA Tracker Competitors?

HC: We think this is a unique compilation of information that can’t be found anywhere else. There may be law firms that produce similar material for specific clients on a bespoke basis, but we’ve never come across one.

RB: What do users get when they subscribe to FCPA Tracker?

HC: In addition to access to all the investigations, companies, and information fields such as agent’s names, subsidiaries involved, countries mentioned, agencies, and so on, users receive email alerts for all new and updated investigations.

It’s surprising how many updates there are for the disclosures. We’ve added six new FCPA-related investigations disclosed in the past two weeks.  That’s a significant change in the FCPA landscape. In other words, the information is very dynamic and changes frequently. That’s why users are so happy with FCPA Tracker and why we’re so excited to bring this information to companies that want it.

RB: What is the source of the information in FCPA Tracker?

HC: We rely entirely on primary documents. All entries are based on disclosures in SEC filings or self-disclosures by non-issuers where available.

RB: Thank you, Harry. So, for anyone who wants to contact you to get more information on FCPA Tracker, how should they proceed?

HC: The best place to learn more about the product is https://fcpatracker.com. If specific question arise, I recommend contacting us directly through the website.


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This was a fascinating and well-researched article. The discussion about whether the FCPA can truly be tracked highlights just how complex compliance, enforcement, and corporate governance have become in today's global business environment. I especially appreciated the way the article encourages readers to think beyond simple metrics and consider the broader context, including organizational culture, transparency, and accountability. Topics like these are valuable for professionals, students, and anyone interested in ethics and international business because they demonstrate that effective compliance requires continuous attention rather than a one-time effort. I enjoy reading thoughtful articles that challenge readers to look at issues from different perspectives. In my free time, I also follow football, so I regularly visit Kora Live, Koora Live, and…

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