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?
What are the key lessons from the Petrobras FCPA enforcement actin? Find out in this episode of the FCPA Compliance Report, with Stephen Martin.Click to tweet
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).