Everything Compliance-Episode 14

FCPA Compliance Report

Show Notes for Everything Compliance-Episode 14

Topics from Matt:

1. Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a tough Trump Admin enforcement WOULD look like;

2. EU’s GDPR— Do EU regulators really know what they want to do with enforcement of this law; although if they follow the lead of the anti-competition people whacking Google, it could be a big deal;

3. Hui Chen’s departure from Justice Department; both her public rebuke of Trump, and the substance of how she believes her guidance has been mis-interpreted; and

4. Ethical leadership and the lack thereof; the menace of abusing perks and privilege, connecting my posts about Uber’s leaders and Chris Christie vacationing on a closed beach.

Topics from Jay:

1. How do the Campaign Finance Laws mirror/or differ from the FCPA?

2. Will the Russian Collusion Investigation reveal the ultimate FCPA violation?

3. Regarding Walter Shaub’s departure from Office of Governmental Ethics (OGE), does it matter? What is OGE supposed to do and why did it work for the past 40+ years, but fell on deaf ears with the Trump administration?

4. Dovetailing with Matt’s question about a slow H1 for FCPA enforcement and in light of the just released Gibson Dunn FCPA Mid-Year Report, does the current climate (and lack of vigorous enforcement) provide a perfect storm for companies to look the other way if they fall off the E&C wagon, or do we think that companies are still being vigilant in spite of a perception of decreased enforcement?

Rants are at the end of this week’s episode.

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