FCPA Compliance Report-Episode 402, Stephen Martin on the Petrobras FCPA enforcement action
In the Episode, I visit with one of the top outside counsel in field of FCPA and compliance. It is Stephen Martin, a partner at Arnold & Porter. In this episode we deconstruct the Petrobras FCPA enforcement action. Some of the highlights include:
- Why is this the largest FCPA fine ever?
- What happens if a company fails to disclose the violations?
- How does a company begin to rebuild from a corrupt culture?
- Why was there no monitor required?
- What is the true cost of a FCPA enforcement action?
- What did Petrobras do to garner a NPA?
- How does this enforcement action incentivize self-disclosure going forward?
- What are the lessons to be learned by the compliance professional?
The Petrobras FCPA enforcement action came in the form of a Non-Prosecution Agreement (NPA) with the Department of Justice (DOJ) and Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC).
