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FCPA Update: Declination and New Indictment

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Manage episode 502323996 series 3521257
Content provided by Michael Volkov. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by Michael Volkov or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://podcastplayer.com/legal.

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed - the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies should expect, and why individuals are squarely in the crosshairs. Taken together, these cases remind listeners that while priorities may shift, the fundamentals of disclosure, cooperation, and accountability remain very much alive.

You’ll hear him discuss:

  • Why Liberty Mutual’s $4.7 million disgorgement shows DOJ is sticking closely to its Corporate Enforcement Policy
  • How voluntary disclosure and cooperation continue to all but guarantee a declination
  • The details behind Liberty Mutual’s misconduct in India and the factors DOJ weighed in its decision
  • What the Pemex indictment tells us about DOJ’s push to hold individuals accountable
  • The role of disgorgement in DOJ resolutions and whether the policy might be applied with more flexibility going forward
  • How luxury goods and personal perks were used in the Pemex scheme and why DOJ zeroed in on those details
  • What these developments signal for companies trying to strengthen compliance programs in a shifting enforcement landscape

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

  continue reading

384 episodes

Artwork
iconShare
 
Manage episode 502323996 series 3521257
Content provided by Michael Volkov. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by Michael Volkov or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://podcastplayer.com/legal.

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed - the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies should expect, and why individuals are squarely in the crosshairs. Taken together, these cases remind listeners that while priorities may shift, the fundamentals of disclosure, cooperation, and accountability remain very much alive.

You’ll hear him discuss:

  • Why Liberty Mutual’s $4.7 million disgorgement shows DOJ is sticking closely to its Corporate Enforcement Policy
  • How voluntary disclosure and cooperation continue to all but guarantee a declination
  • The details behind Liberty Mutual’s misconduct in India and the factors DOJ weighed in its decision
  • What the Pemex indictment tells us about DOJ’s push to hold individuals accountable
  • The role of disgorgement in DOJ resolutions and whether the policy might be applied with more flexibility going forward
  • How luxury goods and personal perks were used in the Pemex scheme and why DOJ zeroed in on those details
  • What these developments signal for companies trying to strengthen compliance programs in a shifting enforcement landscape

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

  continue reading

384 episodes

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