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 and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks.

Some of the highlights include:

  • Who is responsible for the continued violations after initial discovery, the subsidiaries or the parent?
  • What happens when a grandparent ‘speaks sternly’ to a grandchild?
  • Why does a decentralized compliance structure allow for internal abuse?
  • Do your policies and procedures actually support your compliance efforts?
  • As CCO do you have visibility into where customer discounts are going?
  • Should lawyers ever review expense reports from foreign business units?

For additional reading see the following:

Tom’s blog post, Juniper Network FCPA Enforcement Action, on the FCPA Compliance & Ethics Blog.

Matt’s blog post, Juniper Networks Hit on FCPA Charge, on Radical Compliance.

Jonathan Marks considers these points as well as the Board of Directors role in his blog post, Slush Funds and the Juniper Networks FCPA Settlement, on his always great Board and Fraud blog.

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