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FCPA Flash – A Conversation About Voluntary Disclosure On Both Sides Of The Atlantic

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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 Keith Rosen and Pamela Reddy (both attorneys with Norton Rose Fulbright, Rosen in Washington, D.C. and Reddy in London). Along with other Norton Rose attorneys, Rosen and Reedy recently authored an article titled “Self-Reporting Bribery: The Ongoing Dilemma” that caught my eye.  During the podcast, Rosen and Reddy highlight voluntary disclosure dynamics on both sides of the Atlantic and whether the enforcement agencies are actually “shooting themselves in the foot (see here, herehere and here for prior posts) when it comes to encouraging voluntary disclosure.

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FCPA Flash – A Conversation With Becky Rohr (Former DOJ Principal Deputy Chief And Current VP At Hewlett Packard Enterprise) Regarding A Variety Of In-House Compliance Issues

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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 Becky Rohr (former Principal Deputy Chief in the DOJ’s Fraud Section and current Vice President at Hewlett Packard Enterprise where she leads a team handling anti-corruption compliance in the Ethics & Compliance Office). During the podcast, Rohr discusses: (i) the dynamics of post-enforcement action compliance and reporting obligations; (ii) the DOJ’s suggestion in the FCPA Corporate Enforcement Policy regarding appropriate retention of business records; and (iii) her different vantage points surrounding the FCPA given her prior DOJ experience and current corporate experience.

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FCPA Flash: A Conversation With Former DOJ FCPA Prosecutor Bruce Searby Regarding Internship And Hiring Enforcement Actions

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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 Bruce Searby (Searby LLP). Prior to forming this firm, Searby was an enforcement attorney in the DOJ’s FCPA Unit. During the podcast, Searby expands upon points made in his recent article titled “FCPA Liability for Hiring Practices Gain New Credence” including how this enforcement theory is “expansive,” how “no FCPA hiring case has been tested in court,” how in certain of the enforcement actions there are hints that the “government may struggle to establish all the elements required for an anti-bribery violation of the FCPA,” and how “building cases against individuals may be particularly challenging.”

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FCPA Flash Podcast – A Conversation With Harold Kim (U.S. Chamber Institute For Legal Reform) On FCPA Enforcement Policy And Reform

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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 Harold Kim (Executive Vice President, U.S. Chamber Institute for Legal Reform). During the podcast, Kim discusses recent DOJ FCPA enforcement policy developments, the continued viability of an FCPA compliance defenses, as well as the general lack of FCPA policy developments from the SEC.

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FCPA Flash – A Conversation With Alice Fisher Regarding DOJ FCPA Enforcement And Policy

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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 Alice Fisher (Latham & Watkins and former Assistant Attorney General in charge of the DOJ’s Criminal Division). During the podcast, Fisher discusses: the DOJ’s recent non-binding policy discouraging “piling on”;  the DOJ’s FCPA Opinion Procedure program in light of her 2006 comments as Assistant AG that the program should “be something that is useful as a guide to business”; whether the DOJ’s long-standing efforts to encourage voluntary disclosure have failed (for instance in the same above-linked speech Fisher stated: “I can tell you [companies] in unequivocal terms that you will get a real benefit” for voluntary disclosure; whether FCPA enforcement (in terms of resolution vehicles, enforcement theories, DOJ/SEC policy, etc.) has evolved for the better or the worse since her time at the DOJ; and what about the FCPA (the actual statute) or FCPA enforcement (DOJ/SEC enforcement policy, resolution vehicles, etc.) should change and why.

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