Compliance into the Weeds

The J&F FCPA Enforcement Action

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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. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are: 

  • It was one of the most bold, audacious bribery schemes ever.
  • Follow on from Brazil’s largest anti-corruption enforcement action, JBS.
  • What happens when an acquirer of a US listed company is the corrupt entity?
  • Is a target required to perform due diligence on the source of the money used in a M&A deal?
  • Did Pilgrim’s Pride have any responsibility?
  • Are there any US individuals involved?
  • Is Pilgrim’s Pride a victim, entitled to compensation?

    •  Resources

    See Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCA

    See Tom’s exploration the FCPA Compliance and Ethics Blog

    Part 1-Introduction

    Part 2-The Bribery Schemes

    Part 3-The SEC Order

    Part 4-The Plea Agreement

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    Compliance into the WeedsBy Tom Fox
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