Compliance into the Weeds

The WPP Foreign Corrupt Practices Act 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. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP.

Some of the issues we consider are:

  • Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture?
  • What is the role of compliance in M&A?
  • When does a financial incentive become perverse?
  • Where is the DOJ? Where is the SFO?
  • How did WPP avoid a monitor? 

    • Resources

    Matt in Radical Compliance

    WPP Pays $19M on FCPA: An Analysis

     Tom in the FCPA Compliance and Ethics Blog

    Part 1-Background

    Part 2-Structural Compliance Deficiencies

    Part 3-Bribery Schemes

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    Compliance into the WeedsBy Tom Fox
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