FCPA Compliance Report

Jonathan Armstrong on Herbalife from a UK Perspective


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In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this concluding Part 5, I am joined by Jonathan Armstrong and we discuss the enforcement action from the UK perspective under the UK Bribery Act. 

Some of the highlights include:

·       China is a known high-risk business venue.

·       Licenses are required in China for direct sales. 

·       UK Bribery Act not as concerned with the blurring of public and private officials. 

·       Scottish cases provide some interesting analogies.


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FCPA Compliance ReportBy Thomas Fox

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