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 and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are:

  • Why were the facts so egregious?
  • How high up in the organization did the corruption scheme go?
  • Why was the Board’s performance so abysmal?
  • Was the head of Internal Audit in on the bribery scheme?
  • What was the role of short-sellers in bringing this massive fraud to light?

Resources

See Matt’s blog posts on Radical Compliance

Herbalife Pays $123M on FCPA Charges 

See Tom’s 3-part blog post series on the FCPA Compliance and Ethics Blog

The Herbalife FCPA Enforcement Action, Part 1

The Herbalife FCPA Enforcement Action, Part 2

The Herbalife FCPA Enforcement Action, Part 3

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