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 Philip Rohlik (Debevoise & Plimpton). In the episode, Rohlik elaborates on points previously articulated in the firm’s FCPA Update regarding the DOJ’s recent so-called “declinations” – namely that in none of the recent examples did the companies truly benefit from not being charged with a violation that they did not commit. (For background reading, see prior posts here and here).
The term “declination” has certainly become part of the FCPA vocabulary in recent years; however many conversations regarding this topic are muddied because the term lacks a definition. In the episode, Rohlik provides informed insight on recent so-called “declinations” and the episode is a must listen for FCPA practitioners, in-house counsel, and others interested in this important topic.
FCPA Flash is sponsored by the Red Flag Group. The Red Flag Group assists companies in developing and maintaining efficient and effective corporate governance and compliance programs, and has a proven track record in providing integrity due diligence investigations in 194 countries.