Compliance into the Weeds

Herbalife FCPA Enforcement Action

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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 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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    Compliance into the WeedsBy Tom Fox
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