Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. In this episode, I have double trouble as I welcome Scott Garland and Zach Hafer. They worked together for many years at the US Attorney’s Office for the District of Massachusetts, and both are now in private practice, Garland as a Managing Director at Affiliated Monitors, Inc. and Hafer as a Partner at Cooley LLP in Boston. Some of the highlights include:

In this podcast Hafer considers DOJ corporate enforcement through the mechanisms of DPAs and NPAs based upon his tenure as the Criminal Chief. They discussed the need to balance approving prosecutions for general impact vs. based on the case’s individual merits. We also consider how if at all did the Monaco Memo change DOJ focus. Garland leads us through a discussion of compliance issues within a prosecutor’s office, why your compliance philosophy is so critical and some of the biggest issues and situations they both confronted while in the US Attorney’s Office for the District of Massachusetts. We conclude this section with a discussion of receiving compliance advice: what worked and what did not.

We conclude with a discussion of transitioning from DOJ to private practice and both Zach and Scott summarize some of the key questions they are getting from clients. Garland opines on key issues he sees for monitors after Monaco Memo and we conclude with why can proactive monitoring be such a powerful tool.

 Resources

Scott Garland at Affiliated Monitors

Zach Hafer at  Cooley LLP

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