The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

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In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving the Swiss trading company Trafigura.

The topic at hand is the Trafigura FCPA enforcement action, a pivotal case that shines a light on the methods of the Justice Department in dealing with corporate misconduct. This case involves a Swiss company, Trafigura, that was culpable of bribery allegations in Brazil and faced scrutiny for its failure to disclose such schemes.

Matt zeroes in on the absence of a compliance monitor in Trafigura’s case, highlighting the company’s extensive misconduct and questioning whether enhanced compliance reporting could adequately replace such a monitor. He advocates for reforming corporate culture through monitoring and expresses confusion over the DOJ’s inconsistent enforcement strategy.

Fox notes Trafigura’s failure to self-disclose and cooperate and its history of recidivist behavior. He too questions the effectiveness of enhanced compliance reporting as a substitute for a compliance monitor and expresses concern over the Justice Department’s prioritization of fines over reform.

Key Highlights:

Resources:

Matt on Radical Compliance

Tom on the FCPA Compliance and Ethics Blog

 Tom  

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