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 the written posts on FCPA Professor.
This FCPA Flash episode is a conversation with Andrew Levine (Debevoise & Plimpton). Levine is a primary author of the always informative Debevoise & Plimpton FCPA Update and a recent update included an article about the recent Nu Skin FCPA enforcement action that caught my eye.
As highlighted in this prior post, the SEC found that Nu-Skin violated the FCPA’s books and records and internal controls provisions based on a single charitable donation that its Chinese subsidiary made under circumstances in which subsidiary employees concealed relevant information from the parent company and otherwise acted inconsistent with parent company instructions. While the $765,000 settlement amount was not notable, often less high-profile FCPA enforcement actions present the most interesting and troubling issues.
