The FCPA Compliance Report is the longest running podcast in compliance. In this episode, I visit with Ann Sultan, Counsel and Miller & Chevalier. We discuss the firm’s Autumn FCPA Report 2018. It is one of the top quarterly reviews of all things FCPA, anti-corruption and bribery, both domestically and internationally. In this podcast we discuss:
- What are the key themes and numbers that standout for the past quarter?
- We discuss three key cases for the quarter: (a) Beam Suntory-role of Kokesh and strategic use of a tolling agreement; (b) Credit Suisse-compliance risk for hiring in China, and (c) Sanofi-what are the insights into SEC expectations around distributors?
- We consider some of the key International developments: (a) Argentinian Officials Launch Investigation Based on “Bribery Notebooks” Kept by former Government Chauffeur; (b) English Appellate Court Reverses Lower Court Opinion Regarding Attorney Client, and (c) In this UK-Privilege in Internal Investigations (ENRC); and (c) Russian Government Enacts Rules Exempting Companies from Bribery Liability.
- We consider where enforcement may be going in the final quarter of 2018 and then into 2019.
Check out Miller & Chevalier’s Autumn FCPA Report 2018 by clicking here.