FCPA Compliance Report

James Koukios on the Monaco Speech


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In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we take a deep dive into the Lisa Monaco speech from October and related remarks from other DOJ representatives about the DOJ refocus on white collar enforcement and related issues. Highlights of this podcast include:

·       Who is the DAG and what does that position entail?

·       Reinstatement of Yates Memo.

·       Does this change an investigation focus?

·       The new focus on culture and how do you assess corporate culture?

·       What about reports of all violations, enforcements and even investigations even is outside FCPA? 

·       What are the implications of this change?

·       How will all this work with current FCPA Corporate Enforcement Policy?

·       The revocation of Benczkowski Memo. What are the implications?

·       The new focus on monitorships?

·       What about recidivists or those who fail to meet the obligations of their DPA/NPA?

Resources

James Koukios on the MoFo website

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FCPA Compliance ReportBy Thomas Fox

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