In Part I of a two-part series, the top compliance roundtable podcast is back with a review of the new Justice Department’s FCPA Corporate Enforcement Policy.

  1. Mike Volkov sets the stage with background on this new DOJ policy regarding FCPA enforcement going forward, considering what this means from the DOJ/ prosecutorial perspective. He explores why would the DOJ would start with a presumption of a declination when there is arguably a criminal violation? What does this new Policy mean for SEC enforcement? Does this extend any of the concepts we saw as far back as the Yates Memo? 

For Mike Volkov’s post on the new FCPA Corporate Enforcement Policy, see the following: 

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

  1. Matt Kelly considers how might the Justice Department prosecute a case (1) where the company doesn’t meet all the FCPA Program criteria; and (2) how vigorously will prosecutors evaluate a company’s compliance program as part of its investigation? Is this Policy something new or more in the line of a continuation/clarification? Does this new Policy create a real incentive or not for companies to self-disclose? Finally, does this create a true partnership between the DOJ and Business to fight bribery and corruption? 

For Matt Kelly’s post on the new FCPA Corporate Enforcement Policy, see the following: 

DOJ Expands FCPA Pilot Program

The gang is back with rants which follow the discussions. 

The members of the Everything Compliance panel include:

  • Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at
  • Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at
  • Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of Compliance Week. Kelly can be reached at
  • Jonathan Armstrong – Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at