ABB FCPA Resolution

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 explore a subject. In this episode, we consider the ABB Foreign Corrupt Practices Act resolution. We deep dive into the case and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) certification? Some of the highlights included: The background facts. The corrupt supplier’s ABB used to facilitate their bribery and corruption. The convoluted self-disclosure in this matter. (Should they have used Twitter with the notation #committedbribery?) What constituted extraordinary cooperation during the pendency of the investigation? What are the implications of real-time sharing during an investigation? What were the steps which demonstrated the exception remediation? A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out? Did the DOJ change its policy from mandatory CCO certification to discretionary?  Resources Tom has a five-part series in the FCPA Compliance and Ethics Blog Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

Om Podcasten

What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance.