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Friday Roundup

Roundup

Former SEC FCPA Unit Chief Kara Brockmeyer on declinations and voluntary disclosure, Wal-Mart’s global chief ethics and compliance officer on increased standardization in global anti-corruption efforts, scrutiny updates, French first, and for the reading stack.

It’s all here in the Friday Roundup.

Former SEC FCPA Unit Chief Kara Brockmeyer On Declinations and Voluntary Disclosure

Brockmeyer is profiled in this recent Corporate Crime Report Q&A. (See here for a recent FCPA Flash podcast with Brockmeyer).

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A Focus On Third-Party Practices

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Navex Global recently released this report titled “2017 Ethics and Compliance Third-Party Risk Management Benchmark Report.” I am always a bit skeptical of such survey data given that the results often seem to dovetail nicely with the product offering of the company publishing the survey. Indeed, a section of the report is titled “About Navex Global’s Third-Party Risk Management Solution.”

Moreover, I often wonder whether such surveys are even statistically valid. For instance, the survey was based on 427 survey respondents, with approximately 40% of respondents coming from large companies, and approximately 15% of respondents coming from the banking/financial services.

In any event, as highlighted below there are certain survey findings which caught my eye.

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The Challenges Of Detection And Prevention

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The recent Sutherland Springs church massacre. The recent New York City bike path attack. Before that, the bridge attack in London. Before that, the shooting at the Fort Lauderdale airport. Before that, the shooting at an Orlando nightclub.

These recent instances, and several other similar acts of violence, have little in common with alleged Foreign Corrupt Practices Act offenses.

Except there is often a common thread in terms of the challenges of detection and prevention.

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Deputy AG Rosenstein – “We Should Never Use The Threat Of Federal Enforcement Unfairly To Extract Settlements”

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Yet another speech by Deputy Attorney General Rod Rosenstein to pass along (see here and here for other recent speeches).

Yesterday, Rosenstein deliver this morning keynote address at the U.S. Chamber Institute for Legal Reform. Among other things, Rosenstein stated: “Corporate enforcement and settlement demands must always have a sound basis in the evidence and the law. We should never use the threat of federal enforcement unfairly to extract settlements.”

Was this merely an unobjectionable forward-looking statement or perhaps a subtle criticism of the Obama administration during which certain people felt that the DOJ often did just that? For instance, see here for a prior post highlighting former Deputy AG David Ogden’s speech criticizing the DOJ’s leverage-based enforcement approach as well as this FCPA Flash podcast episode during which Ogden further elaborates on the issues.

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FCPA Flash – A Conversation With Claudius Sokenu

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The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Claudius Sokenu. Sokenu is among a small number of individuals who has experienced the FCPA from three different vantage points. First, Sokenu was Senior Counsel at the SEC’s Enforcement Division where he worked on FCPA matters. Second, Sokenu was a partner at various leading law firms where his practiced focused on the FCPA. Currently, Sokenu is Deputy General Counsel, Global Head of Litigation, Global Head of Compliance, and Global Head of Legal-Supply Chain at Andeavor (a Texas-based refining, marketing and logistics company).

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