This Week in FCPA-Episode 128

Goldman Sachs has a very bad week, most particularly around its role in the 1MDB scandal. Tom and Jay consider that story and look at some of the week’s top compliance and ethics stories. 

1. Malaysian officials call for Goldman Sachs to return the $600MM profits it made on the 1MDB bond sales. Stephania Palma reports in the Financial Times. (sub req’d) Goldman Sachs reserves up to $1.8bn to pay for the scandal. Sam Rubenfeld reports in the WSJ Risk and Compliance Journal. Tom has a 3-part series on the matter. Part I-background facts in the guilty plea and indictments, Part 2-the bribery and money-laundering schemes and Part 3-what does it all mean for compliance professionals.
2. New academic reports shows better whistleblower programs save companies money. For the full report, click here. Matt Kelly has two posts on Radical Compliance (here and here). Tom blogs about it on the FCPA Compliance and Ethics Blog.
3. What happens when a compliance professional is not up for the job. David Crow looks at a FCA investigation in the Financial Times. (Sub req’d)
4. Who is Responsible for Ethics? Marsha Ershagahi Hames explains in LRN’s Blog.
5. Did the Hoskinsdecision change any requirements around due diligence on intermediaries or other third-parties? Eric Lochner opines in the FCPA Blog.
6. Does the recent Stryker FCPA enforcement action change the requirements for per diem expense reimbursements? Kyden Creekpaum writes in the FCPA Blog.
7. Does a Golden Passport portend corruption? Dick Cassin explores in the FCPA Blog.
8. Magistrate recommends PdVSA suit alleging recoupment of bribery proceeds by tossed. Carol Balado reports in com. (sub req’d)
9. Is the (SEC) glass half-full or half-empty? In half-full article, FCPA Unit head says more industries about to be sweep. Ryan Barber in com (sub req’d) In the half-empty department, Co-Director of Enforcment, Stephanie Akavian says its impact, not numbers that matter (meaning the numbers are way down). Francine McKenna reports in MarketWatch.
10. Ever wonder how a SEC investigation begins? Dan Portnov explains it all on Grand Jury Target.
11. Looking for the top training on how to operationalize your compliance program? Tom announces a new Compliance Master Class to be held in NYC November 12 & 13, hosted by Jonathan Marks and Baker Tilly. For agenda, more information and registration details click here.
12. Tom premiers new podcast offering, the Daily Compliance News on the Compliance Podcast Network. Have cup of coffee and catch up on the day’s top compliance stories with the Compliance Evangelist. 

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.