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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Mar 5, 2018

In this podcast I welcome back John Hanson, founder and President of the International Association of Independent Compliance Monitors (IAICM) the only professional group for independent corporate monitors. The IAICM was announced one year ago in conjunction with the ABA White Collar Conference. At it's one-year anniversary, Hanson returns to the podcast to reflect on the growth the IAICM, assess the first year of IAICM, discuss of the highlights of the first year for you as President of the IAICM and then goes into some of the goals or initiatives for the IAICM in year 2.

With the announcement of the Justice Department’s Evaluation of Corporate Compliance Programs in February and new FCPA Corporate Enforcement Policy in November, the landscape for monitors will likely continue to evolve in 2018. Hanson and I consider what these and other DOJ announcements may portend, including the following questions:

  • How will the Trump administration impact corporate criminal liability and the Monitorships that accompany 30-40% of those matters?  
  • What will be the effect on the use of Monitors by DOJ's new position with regard to FCPA matters?  
  • How will the use of Monitors be impacted by new leaders at the SEC?  
  • Will Federal Judges continue to intervene in plea and deferred prosecution agreements?  
  • How much more will the use of Monitors continue to grow in the wake of changes internationally, including especially Canada, Brazil, Australia, the UK, and the EU?

As with all visits with Hanson, they are thoughtful, well-informed and very insightful. If you practice in the FCPA world or in the broader international anti-bribery/anti-corruption sphere, you will not want to miss this interview.

For more information on the IAICM, including membership, resources, its Code of Conduct and services, check out the website IAICM.org.  

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