FCPA Compliance Report-Episode 325

FCPA Compliance Report-Episode 325

In this podcast, Marc Bohn and James Tillen from the firm of Miller & Chevalier, discuss their recent publication entitled, "Evaluating FCPA Pilot Program: Declinations on the Rise" where they review the state of Department of Justice's Foreign Corrupt Practices Act declinations after one year of the agency's enforcement Pilot Program, which sought to promote greater accountability for companies and individuals who violate the FCPA, while rewarding those who voluntarily self-disclose violations and cooperate with investigations and remediation efforts. They discuss the following issues: Do the numbers show any increase in declinations in 2016 over the past few years? What are the conditions to obtain a declination? Is any one as more important or are they of equal importance? Is there any reason not to publicize all declinations? They discuss how SEC enforcement is a factor in DOJ calculus in determining whether or not to grant a declination. In 2016 there were two declinations which involved privately held companies and hence no SEC prosecution. They explain how the DOJ got to profit disgorgement. They prognosticate the tea leaves, on what might be the fate of the the Pilot Program going forward. For additional reading on FCPA enforcement in 2017, see Miller & Chevalier's FCPA Spring Review 2017. Learn more about your ad choices. Visit megaphone.fm/adchoices

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Episoder(1614)

The Scoular FCPA Enforcement Action: Customs Bribes, Cartel Links, and New Compliance Expectations

The Scoular FCPA Enforcement Action: Customs Bribes, Cartel Links, and New Compliance Expectations

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Matt Ellis to discuss a newly announced FCPA enforcement action invol...

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AI in Compliance and Eastward AI’s Continuous Risk “Reality Check”

AI in Compliance and Eastward AI’s Continuous Risk “Reality Check”

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Gerry Zack, and they discuss the growing use of AI in compliance and ...

13 Jul 29min

Managing Compliance and National Security Risks When Doing Business in the DRC, Part 2

Managing Compliance and National Security Risks When Doing Business in the DRC, Part 2

In this episode, Tom Fox welcomes David Simon, Partner at Foley & Lardner; Jack Korba, Of Counsel at Foley & Lardner; and Olivier Bustin, a Partner at Pinsent Masons, to discuss doing business in and ...

29 Jun 24min

Managing Compliance and National Security Risks When Doing Business in the DRC, Part 1

Managing Compliance and National Security Risks When Doing Business in the DRC, Part 1

In this episode, Tom Fox welcomes David Simon, Partner at Foley & Lardner; Jack Korba, Of Counsel at Foley & Lardner; and Olivier Bustin, a Partner at Pinsent Masons, to talk about doing business in a...

22 Jun 29min

Data Defensibility: The Foundation of AI Readiness with George Tziahanas

Data Defensibility: The Foundation of AI Readiness with George Tziahanas

In this episode, Tom Fox welcomes George Tziahanas, VP of Compliance and Associate General Counsel at Archive360, who brings a practical legal and governance perspective to the challenges of AI and da...

15 Jun 30min

Leading with Invitation: Communications, Leadership, and Compliance with Dr. Dennis Cummins

Leading with Invitation: Communications, Leadership, and Compliance with Dr. Dennis Cummins

In this episode, Tom Fox welcomes Dr. Dennis Cummins to discuss his latest book, Invitational Selling: The Human Connection Advantage. Dr. Cummins is a renowned expert in the field of invitational sel...

8 Jun 31min

Matt Ellis on Cartels, FTO Risk, and Corporate Compliance in Latin America

Matt Ellis on Cartels, FTO Risk, and Corporate Compliance in Latin America

In this episode, Tom Fox welcomes Matt Ellis of Miller & Chevalier about the ACI “Cartels, TCOs and Compliance in Latin America” forum (July 20–21, Washington, DC) and why cartel/TCO/FTO risk is a tim...

1 Jun 25min

Report from Compliance Week 2026 on AI Sessions

Report from Compliance Week 2026 on AI Sessions

In this episode, Tom Fox takes a solo turn behind the mic to report on the AI tracks from the recently concluded Compliance Week 2026 conference. He highlights two AI tracks: practical “creative” use...

11 Mai 21min

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