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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:

“In a newly created position, he will work as the section’s resident compliance and big data expert, advising prosecutors on the policies and procedures that companies put in place to stop employees from violating laws or internal policies.”


“The addition of Mr. Galvin to the section is an unusual career pivot for the executive, who has never worked in government. He also is an atypical hire by the Justice Department, whose ranks are primarily staffed with attorneys focused on investigating, prosecuting and bringing cases to trial.

His hiring is part of an effort by Justice Department leadership across several successive administrations to add compliance expertise to the agency’s white-collar crime programs, including its enforcement of the Foreign Corrupt Practices Act, an antibribery law.”

In this May 2021 FCPA Flash podcast, Galvin talked about AB InBev’s compliance systems. At the approximate 20 minute mark of the podcast, Galvin said that he supported an FCPA compliance defense. Among other things, he stated:

“What I would like to see … is to move governments to [the] point where they are creating safe harbors for having measurably effective compliance programs.”


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