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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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What Do These Phrases Even Mean?

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We are all prone to using vague and ambiguous terms or cliches or buzzwords at times.

However, in my opinion, many in the compliance community seem to have developed a vocabulary all of their own that, at first blush, sounds sophisticated but in reality is merely gobbledygook masquerading as expertise.

This recent post by a respected compliance practitioner is a good example.

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Does Fear Motivate Compliance?

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One component of Foreign Corrupt Practices Act compliance so-called “best practices” is training. But what type of training best minimizes FCPA risk?

Consider two types of training: the first legalese, fear-based training and the second, spot the issues type of training.

As to the first type of training, what sort of participate reaction would result if the trainer begins with saying something along the following lines: “Today I will be talking about a U.S. law that makes it a crime to bribe foreign government officials to get business. Your failure to abide by this law could result in you going to jail.”

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Speaker Fees

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Numerous Foreign Corrupt Practices Act enforcement actions have involved the enforcement theory that various foreign health care professionals (HCP’s) are “foreign officials” and thus occupy a status similar to a President, Prime Minister, or other traditional bona fide government official.

Several of these enforcement actions have included allegations that HCP’s received speaker fees or honoraria from pharmaceutical or medical device companies.

For instance, the Sanofi enforcement action included allegations that an HCP was provided “with consulting, speaking, and clinical trial fees over a period of years despite the lack of documentation or other support to demonstrate the services had been provided.”

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