Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom Fox welcomes back Michael Volkov as they take a deep dive into the ABB, Albemarle and SAP FCPA enforcement actions to try and unpack the DOJ’s pivot away from heavy penalties for recidivists to prioritizing self-disclosure above all else.  

Volkov's perspective on the Department of Justice's (DOJ) FCPA enforcement actions is both critical and analytical, shaped by his extensive experience. He underscores the necessity of transparency and explanation in the factors considered by the DOJ, highlighting its significance to practitioners in the field. Volkov also recognizes the shift in DOJ policy towards data-driven compliance, requiring companies to provide data to substantiate their conclusions and demonstrate their compliance efforts. He further notes the evolving landscape of voluntary disclosure and remediation, suggesting these areas are now pivotal in the DOJ's enforcement approach. Volkov's insights reflect a nuanced understanding of the changing dynamics in FCPA enforcement and the imperative for companies to adapt to these shifts.

 Key Highlights:

Resources:

Volkov Law Group

Corruption, Crime and Compliance

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

Learn more about your ad choices. Visit megaphone.fm/adchoices