FCPA Compliance Report

Kevin Abikoff and Aline Osorio on Distribution of Proceeds from ABC Enforcement Actions

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In the Episode, I am joined by Kevin Abikoff, partner at Hughes Hubbard and Aline Osorio, International Specialist at the firm. The co-authored a very interesting article entitled “Corruption Settlements, Coronavirus And The Road Paved With Good Intentions”. The paper considered where should the proceeds of government enforcement activity be placed and who should get to decide. It was a fascinating topic that I have long considered and wanted to podcast on. 

Some of the highlights include: 

  • What was the genesis of the paper “Corruption Settlements, Coronavirus And The Road Paved With Good Intentions”?
  • Where do funds collected in FCPA cases go in US?
  • Where do funds collected in anti-corruption actions in Brazil go?
  • What was the driving force behind Brazil dedicating monies from the Petrobras settlement to benefit education and the environment in Brazil?
  • What has the current government requested be changed?
  • Who should decide where fines and penalties go? Prosecutors? Executive Branch? Other elected officials? Non-elected officials?


    • You can download a copy of their white paper Corruption Settlements, Coronavirus And The Road Paved With Good Intentions by clicking here.

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    FCPA Compliance ReportBy Thomas Fox
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