Compliance into the Weeds-Episode 24

In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes a regulatory scheme for FCPA compliance. Matt and I discuss the pros and cons and how the SEC Chairman designate Jay Clayton may view the issues. We then take a brief look at the arrest of VW executive Oliver Schmidt and both conclude that it presents ZERO problems for any Chief Compliance Officer or compliance practitioner going forward. 

For additional reading, see

1. Matt Kelly blog post on Doty article, "Ye Olde Plan for FCPA Compliance";
2. Matt Kelly blog post on Oliver arrest, "Enough About CCO Liability"
3. Tom Fox blog post on Oliver arrest "Honey I Think We Should Vacation at Home this Year"' and 
4. Jim Doty article "Toward a Reg. FCPA: A Modest Proposal for Change in Administering the Foreign Corrupt Practices Act"