In Opinion Release 12-02, certain Requestors, which were 19 non-profit adoption agencies located in the US, asked the DOJ about bringing certain foreign governmental officials involved in the foreign country’s adoption process to the US. Can the Requestors do so, without running afoul of the FCPA?

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In the Episode, I visit with one of the top outside counsel in field of FCPA and compliance. It is Stephen Martin, a partner at Arnold & Porter. In this episode we deconstruct the Petrobras FCPA enforcement action.

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The baseball playoffs are here.  For the Sox, the hated Yankees. For the Astros, they begin their World Series defense against the Cleveland Indians. Tom and Jay discuss and take a look at some of the week’s top compliance and ethics stories.

1. Styker is now a two-time FCPA loser. Will there be a third? Sam Rubenfeld reports in the WSJ Risk and Compliance Journal. Dick Cassin reports in the FCPA Blog.
2. In a pique of sanity, Elon Musk settles his SEC lawsuit which might have barred him from serving on the Board of a public company. Tim Higgins and Dave Michaels consider the fallout in the WSJ. Both James Stewart, writing in the NYTand Tom Zanki, in Law360 say the Board needs better oversight.
3. Former Chile mining official settles FCPA charges. Dick Cassin reports in the FCPA Blog. Sam Rubenfeld reports in the WSJ Risk & Compliance Journal.
4. The commentary from the Petrobras FCPA enforcement action continues. Tom runs a 3-part series (Part 1, Part 2& Part 3). Mike Volkov weighs in on Corruption, Crime and Compliance. Andy Webb-Vidal explores the 10 ten takeaways from Operation Car Wash on Corporate Compliance Insights. Jonathan Marks looks at it from the ‘Realm of the Obvious’ in his Board and Fraud blog.
5. MLB reportedly under investigation for FCPA violations in Latin America. Cheryl Ring reports in Fangraph.
6. More on ruling on attorney-client privilege in UK. Sam Rubenfled in WSJ Risk & Compliance Journal reports SFO will not appeal ENRC ruling. Andrew Reeves provides five key takeaways in the FCPA Blog.
7. Panasonic Avionics finally get a monitor. Kelly Swanson reports in GIR.
8. Robbing a national bank, think big. Margot Patrick, Gabriele Steinhauser and Patricia Kowsmann report in the WSJ.
9. Women who have behaved badly. Rosmah Mansor, wife of former Malaysian PM Najib Razak charged with money-laundering, Harry Cassin in the FCPA Blog. SFO moves to sieze assets of Gulnara Karimova the eldest daughter of the late Uzbek President Islam Karimoa. Dick Cassin the FCPA Blog.
10. Want a 50% discount to one of the top compliance conferences around? Join Tom and AMI’s Eric Feldman at CONVERGE18 in Denver on October 9-11. I hope you can join me at the event. For information on the event, click here. As an extra benefit to fans of This Week in FCPA, CONVERGE18 is offering a 50% discount off the registrationEnter discount code TOMFOXVIP.
11. The baseball playoffs are here. Tom and gutless wonder Jay discuss. Tom explains why Jay is a gutless wonder.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.

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Welcome to the only roundtable podcast in compliance. This week’s episode is entirely dedicated to the spectacle of the Ford-Kavanaugh hearings from the past week. Jonathan Armstrong is on assignment so Tom Fox sits in for Armstrong. After the commentary we follow with rants.

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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 take a very deep dive into the increased prevalence of non-GAAP financial reporting.    

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In this special five-part podcast series, I visit with Thomas Sehested, founder and CEO of Gan Integrity. In this series, we will consider how the effective use of technology can drive not only a more effective, operationalized compliance program but make your business run more efficiently. In this Part I, I visit with Thomas Sehested on his journey from professional athlete to tech entrepreneur to compliance solution provider.

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In this special five-part podcast series, I visit with Thomas Sehested, founder and CEO of, Valerie Charles, Chief Strategy Officer and Peter Chang, Head of Customer Success of Gan Integrity. In this Part IV, I visit with Chang on the Gan approach to client success and how it acts towards continuous improvement of a compliance program.

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In this special five-part podcast series, I have visit with Thomas Sehested, Valerie Charles, and Peter Chang all from Gan Integrity. In this Part III, I visit with Thomas Sehested how tech solutions can make not only compliance more efficient but companies run more efficiently and at the end of the day more profitably.

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In this special five-part podcast series, I have visited with Thomas Sehested, founder and CEO of, Valerie Charles, Chief Strategy Officer and Peter Chang, Head of Customer Success of GAN Integrity. In this series, we will consider how the effective use of technology can drive not only a more effective, operationalized compliance program but make your business run more efficiently. In this Part V, I visit with Charles some of her birdseye view of compliance.

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In this special five-part podcast series, I visit with Thomas Sehested, founder and CEO of, Valerie Charles, Chief Strategy Officer and Peter Chang, Head of Customer Success of Gan Integrity. In this series, we will consider how the effective use of technology can drive not only a more effective, operationalized compliance program but make your business run more efficiently. In this Part II, I visit with Charles on her journey from legal to compliance to tech.

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