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. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms.

Some of the issues we consider are:

·      Are DPAs and NPAs simply the cost of doing business?

·      Is the Wells Fargo growth cap a valid model?

·      What about greater DOJ or Monitor oversight? 

·      Longer terms for DPAs?

·      New enforcement tools coming?

·      New review of DPAs and NPAs.

Resources

Matt in Radical Compliance

So What Happens Next with DPAs

Tom in the FCPA Compliance and Ethics Blog

Monaco Speech - Individual Accountability

Monaco Speech - Monitors

Text of DAG Monaco Speech

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