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 Leslie Caldwell. Caldwell is currently partner in the San Francisco and Silicon Valley offices of Latham & Watkins and previously served as the Assistant Attorney General of the DOJ’s Criminal Division. In this role, Caldwell was involved in implementing and promoting the DOJ’s April 2016 FCPA Pilot Program.
During the podcast, Caldwell: (i) offers thoughts on the DOJ’s new “FCPA Corporate Enforcement Policy”; (ii) discusses whether the differences in the new policy (compared to the 2016 FCPA Pilot Program) were considered in 2016; (iii) addresses whether the new policy represents a de facto compliance defense; (iv) talks about the prosecution of individuals; and (v) opines whether the FCPA, as it reaches 40, has been successful in achieving its objectives.
FCPA Flash is sponsored by Kroll. Kroll is trusted by companies and compliance officers worldwide to help prevent, detect, and remediate FCPA challenges with scalable, end-to-end compliance solutions: from high-volume third party screening and automated monitoring, to risk-based due diligence, to complex investigations and monitorships.