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 Philip Rohlik (Debevoise & Plimpton) regarding the recent Dun & Bradstreet enforcement action. As highlighted in this previous post, the enforcement action was unremarkable from a settlement amount perspective, yet serves as a microcosm of the many problems with FCPA enforcement and in the podcast Rohlik: questions just what criminal charges the DOJ actually declined and discusses other issues relevant to the so-called declination; discusses the concerning internal controls standard the SEC invoked in the enforcement action; and takes issue with certain commentary regarding the enforcement action.
FCPA Flash is sponsored by Kreller Group.
For the past 30 years, Kreller has distinguished itself as a best-in-class enhanced due diligence provider. It’s investigative network leverages the talent and integrity of some of the best law-enforcement, military specialists, business correspondents, and government contacts worldwide. With firsthand knowledge of the language, laws, regulations, political and economic climates and data availability in each country, Kreller provides reliable, compliant, and accurate information. A licensed private investigations firm, Kreller’s competitive advantage is experience, quality, commitment, and customer service.
