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:

  1. What are the key themes and numbers that standout for the past quarter?
  2. 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?
  3. 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.
  4. 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.