Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into some of the difficulties around distributors in anti-corruption compliance.

Some of the highlights include:

  • The recent Polycom FCPA enforcement action highlighted several FCPA enforcement actions from 2018 involving distributors.
  • How do discounts, coupons, rebates, and sales devices circulate among your company, distributors, and end customers? Distributors present these and other issues separate from sales agents and employees.
  • What do the Sanofi and Stryker enforcement actions tell us around compliance?
  • Why does Document Document Document continue to be a mantra for anti-corruption compliance?

For additional reading see Matt’s blog posts Distributors, FCPA, and Internal Controls — Lessons for Anti-Bribery & Corruption Programsin Navex Global’s Ethics and Compliance Matters

For more on the Polycom FCPA enforcement action, see Tom’s blog post, “Follow the Money Through Distributors

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