This Week in FCPA-Episode 78

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

Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement Policy and stated that it is now “incorporated into the United States Attorneys’ Manual.” See Tom’s article in the FCPA Compliance Report. See report by Sam Rubenfeld and Henry Cutter in WSJ Risk and Compliance Journal. Also see Matt Kelly’s thoughts in Radical Compliance and those of Doug Cornelius in Compliance Building.

1. SBM Offshore pays $238MM to settle its outstanding FCPA matter. See article by Dick Cassin in the FCPA Blog. Sam Rubenfeld reports in the WSJ Risk and Compliance Journal.
2. SBM executives who engaged in bribery and corruption continue to be indicted. This time by the UK Serious Fraud Office. Dick Cassin reports in the FCPA Blog.
3. The FIFA trial is ongoing in NYC. It has featured bag men, bribery registries and death threats (or simple neck stractching). See stories in Bloomberg, the Miami Herald and wftv.com.
4. Mike Volkov has a three-part series on converging AML compliance into overall corporate compliance regime. Part I; Part II; and Part III.
5. Adam Turteltaub visits with Rebecca Walker on assessing your compliance program on the SCCE podcast, Compliance Perspectives.
6. Roy Snell says you must have a passion for compliance, on the SCCE blog.
7. The Supreme Court hears arguments on whistleblower protection from retaliation under Dodd-Frank in the matter of Digital Realty Trust. See article in secactions.com.
8. Join Tom’s monthly podcast series on One Month to a More Effective Compliance Program. In December, I consider discuss the use of written standards in a best practices compliance program. It is available on the FCPA Compliance Report, iTunes, Libsyn, YouTube and JDSupra.
9. The Everything Compliance gang is back for another informative episode. In Episode 21, we discuss the ATT merger issues, the Paradise Papers, issues around corporate monitors and consider DOJ comments on FCPA enforcement. You can listen to Episode 21 here. We put together an eBook of their reflections from the recent SCCE 2017 Compliance and Ethics Institute. It is available for download free on JDSupra. It is also available on the Affiliated Monitors site by clicking here.