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Friday Roundup

Roundup

Transparency, hilarious, fact-checking, little sense, just saying, and for the reading and listening stack. It’s all here in the Friday roundup.

Transparency

The Project on Government Oversight (POGO) recently this document titled “Baker’s Dozen: 13 Policy Areas That Require Congressional Action” noting that a “lack of transparency around enforcement of the FCPA leaves lingering questions about its utility.” POGO then proposes:

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How Not To Communicate FCPA Compliance Expectations

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A component of Foreign Corrupt Practices Act compliance is for a business organization to communicate its unique risks and its specific policies and procedures throughout its organization in a way that resonates with the intended audience.

In short, effective communication is a key factor in minimizing risk under the FCPA and related laws.

Yet, as highlighted below by a real company’s FCPA compliance policy, business organizations can fall short in this regard.

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Friday Roundup

Roundup

Consistently damaged, across the pond, scrutiny alerts and updates, and for the reading stack. It’s all here in the Friday roundup.

“Consistently Damaged”

In this 12 minute video, Neil Bruce (CEO and President of SNC-Lavalin) describes his frustration for how the company is not being offered a remediation agreement (Canada’s term for a deferred prosecution agreement) in connection with its long-standing scrutiny. (See here and here for prior posts).

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FCPA Flash Podcast – A Conversation With Kevin Abikoff Regarding FCPA Compliance Challenges And Other Developments

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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 Kevin Abikoff (Co-chair of Hughes Hubbard & Reed’s Anti-Corruption and Internal Investigations Practice Group). In the podcast, Abikoff discusses: FCPA compliance challenges; his top two legal or policy developments in 2018 in the FCPA space; and whether the FCPA has truly been successful in achieving its objectives.

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FCPA Flash Podcast – A Conversation With Joseph Moreno Regarding The Limits Of An FCPA Compliance Program

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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 Joseph Moreno (a former federal prosecutor and currently a partner in Cadwalader’s White Collar Defense and Investigations Group). Moreno, along with other Cadwalader attorneys, recently authored this article “When Realities Test the Limits of Your FCPA Program” that caught my eye. During the podcast, Moreno discusses: the origins of the article; how excessive risk aversion regarding corporate hospitality can have negative consequences; what Congressional leaders in the mid-1970’s who led the FCPA movement might think about certain current enforcement theories; and what might happen if certain enforcement theories were actually subjected to judicial scrutiny.

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