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FCPA Flash Podcast – A Conversation With Matthew Galvin Regarding ABInBev’s BrewRight Compliance System

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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 Matthew Galvin (Global Vice President, Ethics & Compliance at AB-InBev). During the podcast, Galvin talks about the company’s BrewRight compliance system including: the origins of BrewRight; what BrewRight is; and how it minimizes FCPA (and other) risk. Galvin also discusses whether companies that adopt similar compliance systems should be able to avail themselves of a “compliance defense.”

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Just Don’t Call It Bribery

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Here in Packerland, there is much angst over the apparent reluctance of Aaron Rodgers to return to the Green Bay Packers as quarterback.

This is no small matter as Rodgers is the reigning NFL MVP and … well … this is Packerland.

Some Packer fans are not sitting on the sidelines as passive observers. For instance, Mr. Brews Taphouse is offering Rodgers (along with his fiance) free burgers and beer for life if he agrees to finish his career with the Packers.

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This Week On FCPA Professor

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FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

In this FCPA Flash podcast episode, a former DOJ FCPA prosecutor: (i) shares his experiences trying FCPA cases including the difference between “FCPA violations” and “FCPA violations that can be proven at trial”; (ii) discusses underappreciated aspects of DOJ FCPA enforcement; (iii) opines whether the government is vulnerable on some of its FCPA enforcement theories; and (iv) suggests a change to FCPA enforcement.

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Scrutiny Alerts And Updates

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Ormat Technologies

As highlighted here, earlier this year a “short seller” alleged that Ormat Technologies (a Nevada-based geothermal power company with shares traded on the New York Stock Exchange that owns and operates power plants in Kenya, Guadalupe, Guatemala, Honduras and the United States) was “engaged in what we believe to be widespread and systematic acts of international corruption.”

In its most recent quarterly filing, Ormat stated:

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There Is No FCPA News Today

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Really, there isn’t!

There is nothing in the FCPA space today particularly newsworthy warranting your attention. Sure, I could have drawn compliance lessons from the sun rising this morning or discussed the lessons learned from being a head Varsity boys basketball coach for two years now and related that to compliance (there are clear parallels), or even the lessons I’ve learned over the past two weeks raising six baby chickens and some how relating it to the Tyson Foods FCPA enforcement action.

But who really cares!

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