FCPA Compliance Report

Mike DeBernardis on Q3 FCPA Enforcement and Related Issues

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In the Episode, I visit with Mike DeBernardis, Counsel and Hughes Hubbard. We take a look back at the FCPA world in Q3. It started off with a bang and never slowed down. 

Some of the highlights include:

  1. The quarter started off with a bang-Novartis US and never slowed down. 
  2. How and why did Novartis US, First Energy in Ohio and Commonwealth Ed in Illinois change the discussion around domestic corruption?
  3. What were some of the key lessons from the Herbalife FCPA enforcement action? Why is it so important to obtain experienced White-Collar Counsel in a serious FCPA matter?
  4. What were top 3 takeaways from the release of the FCPA Resource Guide 2nd edition?
  5. Sargeant Marine was a rare criminal FCPA plea. What is the significance of the case?
  6. The Alexion SEC enforcement action in July was relatively small but had some interesting lessons. What were key takeaways from the case?
  7. Do you see continue aggressive FCPA enforcement by the DOJ/SEC?
  8. What are you telling clients about their compliance programs going into the next 12 months?


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