As Tom and Jay prepare for the December holiday season, they consider the DOJ/SEC’s strong affirmation that aggressive FCPA enforcement is here to stay, changes to the Yates Memo/plea for increased cooperation and some of the week’s other top compliance and ethics stories.

  1. DOJ/SEC reaffirm importance of FCPA prosecutions. Christopher Cole reports on regulators remarks at ACI National FCPA Conference in Law360. Going in another direction, Deputy Attorney General John Cronan discusses the importance of the public private partnership in fighting bribery and corruption. Matt Kelly reports on his speech by on Radical Compliance. For full text of speech, see here. Finally Rod Rosenstein announces cut backs to the Yates Memo in a speech.
  2. Facebook woes continue as a cache of its internal documents end up in Britain’s House of Commons immediately before a hearing. Adam Satariano reports in the New York Times. The hearing is held with an empty chair for Mark Zuckerburg who was too busy to drop by. Tom and Jonathan Armstrong have their first emergency podcast on Life with GDPR to explain it all.
  3. How do you establish pace and scope in a SEC investigation? Dan Portnov explains in Grand Jury Target.
  4. FIFA Judge Balks At $116M Restitution Bids In Bribery Case. Stewart Bishop reports in Law360.
  5. Russia’s largest telecom company, MTS reserves $840MM for FCPA resolution. Harry Cassin reports in the FCPA Blog.
  6. Former Venezuelan National Treasurer, Alejandro Andrade sentenced to 10 years in prison formoney laundering in accepting over $1bn in bribes. Harry Cassin reports in the FCPA Blog. Sam Rubenfeld reports in the WSJ Risk & Compliance Journal.
  7. What is the role of the human element in internal controls. Tom Gorman explores this interesting issue in SEC Actions.
  8. 11 Latin American law firms join forces to create a template for best practices in an anti-corruption investigation. Melissa Van Brunnersum reports.
  9. In Houston over the next couple of weeks? Tom will be speaking at the December meeting of the ACFE Houston Chapter on December 11 and leading meetings of the Houston Compliance Roundtable, the midtown group meets at Rowan Drilling on December 12 and the Woodlands group meets on December 13 at Nexio. For information on the Roundtables, contact Tom. To register for the ACFE Houston Chapter event, click here.
  10. Interested in learning some compliance lessons through travel and history? Check out Tom’s 5-part podcast series of compliance lessons from Venice. Part I-Doing Compliance the Old-Fashioned Way; Part II-the Arsenale and Incentives in Compliance; Part III-Selfie Sticks and Risk Assessments; Part IV-the Venetian Gondolier; Part V-Into the Lion’s Mouth. All podcasts are also available on iTunes, JDSupra, YouTube and Libsyn.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.

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