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Deputy Assistant AG Monaco On …


Recently Deputy Attorney General Lisa Monaco delivered this speech at the American Bar Association National Institute on White Collar Crime.

Topics discussed included: “inspiring a culture of compliance,” “promoting compliance through compensation and clawback programs,” and “accountability.”

Monaco began her speech as follows:

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“The Carrots We Offer Have Never Been Juicier”


I have been reading speeches by Department of Justice enforcement officials on white collar crime, compliance, and related issues for approximately 15 years.

I take many of these speeches with a grain of salt because more often than not, the substance of the speech have been articulated before and because I am not seeking to actively market DOJ policy as a way to expand my services (as so many law firms and others do).

Many of these speeches have the look and feel on an “infomercial” in which a DOJ official is trying to market and sell its latest widget.

So it was with this recent speech by Deputy Assistant Attorney General Lisa Miller Delivers in which she stated that the “carrots we offer have never been juicer.”

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New DOJ Compliance Hire Supports An FCPA Compliance Defense


As reported here, Matt Galvin, Anheuser-Busch InBev SA’s former global compliance chief, will join the Justice Department’s fraud section next week.

As stated in the article, “Mr. Galvin is best known among corporate compliance professionals for spearheading the development at AB InBev of a cutting-edge analytics platform that analyzes troves of corporate data to identify risky business partners and suspect payments.”

According to the article:

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Incentives To Induce Action


There is very little in common with COVID vaccination rates and FCPA compliance – except that the government encourages both.

Yet in one instance, the government provides meaningful incentives to induce action and in the other instance the government does not.

As to COVID vaccinations, states are offering the following incentives to encourage more people to get vaccinated: lotteries, scholarships, pre-paid grocery cards, fishing and hunting licenses, passes to state parks, even custom hunting rifles and shotguns. Several states are automatically entering people who have been vaccinated into lotteries that pay out $1 million or more.

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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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