James Koukios on International Anti-Corruption Developments from April 2018

FCPA Compliance & Ethics Report, Episode 390


In this episode, James Koukios highlights six developments from Morrison and Foerster’s April Top Ten. Topics include:

  • D&B Declination for FCPA violations: How did the company get such a great result?
  • IMF “Steps Up” Engagement on Governance and Corruption: On April 22, 2018, the IMF announced that its Executive Board had endorsed a new framework for “stepping up” engagement on governance and corruption in its member countries. What does this mean for companies?
  • Individual prosecutions continue related to PDVSA: What does this mean, together with the tightening sanctions against Venezuela for US companies still trying to do business in that country or stuck it out hoping for regime change.
  • Aruban Official and Florida-based Telecom Executive Plead Guilty in Connection with Bribery Scheme: Use these guilty pleas to discuss the bookends of corruption; bribe payor and bribe receiver. How does the DOJ look at this problem and what tools are available to prosecutors?
  • Companies Currently Doing Business in these Regions Need to Take a Close Look at Their Operations: James and  Tom have suggested South Africa and Malaysia. Are there others the DOJ might be looking at?
  • Added Feature: We move to a current event, the news of a Subpoena issued to Glencore by the Justice Department, in part related to a FCPA investigation. We consider what delivery of a Subpoena means from the DOJ and company perspective.

Listen to James Koukios regarding recent anti-corruption developments.



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