Compliance into the Weeds: Episode 98

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the Benczkowski Memo and what it means for not only the monitor selection process but for compliance officers who may be in front of the Justice Department in a FCPA investigation.   

Some of the highlights from this podcast are:

1. Will there be corporate monitors going forward?
2. Tom argues this memo sets out a road map for any company under FCPA investigation to avoid a monitor.
3. Matt wonders if this memo will assuage mergers and acquisition liability for inadequate pre-acquisition due diligence.

We unpack of all these points and consider strategies going forward.

For more reading: see Matt’s piece New DOJ Policy on Corporate Monitors and see Tom’s blog posts Astros Heading to Back-to-Back as DOJ Announces New Monitor Policy and Back-to-Back (again): More on the Benczkowski Memo.