This Week in FCPA-Episode 76

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including:

1. Justice Department announces 4 guilty pleas and one indict as follow on prosecutions from the Rolls Royce corruption case. See Tom’s article in the FCPA Compliance Report. See Sam Rubenfeld’s article in WSJ Risk and Compliance Report.
2. Dick Cassin asks if the SEC is targeting foreign companies for FCPA enforcement. See article by Dick Cassin in the FCPA Blog.
3. Hui Chen suggests there should be more FCPA enforcement of US domestic companies, reviews monitorships and the FCPA Pilot Program. Henry Cutter interviews Chen in the WSJ Risk and Compliance Report.
4. Saudi Arabia has a corruption crackdown. What does it mean for the compliance practitioner? See Tom’s article in FCPA Compliance Report.
5. What happens if your General Counsel is also your CCO? Joe Murphy explores this conundrum in the SCCE Blog.
6. What will become of the DOJ’s Evaluation of Corporate Compliance Programs? Matt Kelly explores in Radical Compliance.
7. What do the Paradise Papers mean for the compliance practitioner. Sam Rubenfeld considers in the WSJ Risk and Compliance Journal.
8. Mike Volkov has a two-part series on the intersection of COSO and compliance. Part I on the framework; Part II on using the framework to break down siloes.
9. AML concerns. Adam Davidson returns to the Compliance Report-International Edition podcast to explain the intersection of money-laundering and the Trump business empire. DAG Rod Rosenstein discusses the intersection of FCPA, AML prosecutions and international investigations in a speech to Clearing House 2017 Annual Conference.
10. Join Tom’s monthly podcast series on One Month to a More Effective Compliance Program. In November, I consider how a 360-degree view of communications can enhance your compliance program. This month’s sponsor is the Dun & Bradstreet. It is available on the FCPA Compliance Report, iTunes, Libsyn, YouTube and JDSupra.
11. FCPA Master Class Training in NYC on November 28 & 29. For information and registration, go here.