In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top world’s top compliance practitioners and commentators on compliance. They include, Jay Rosen-Mr. Monitor; Mike Volkov-Editor of Corruption Crime and Compliance; Jonathan Armstrong-partner at Cordery Compliance in London; Cecilia Fellouse-Guenkel-Secretary General, The Circle of Compliance and Tom Fox-the Compliance Evangelist. In today’s Episode 2, Mike Volkov considers that US trade sanction enforcement involving Airbus.

Highlights include:

  • How was Airbus subject to US trade sanction jurisdiction?
  • This is one of the few cases where the DOJ focused on anti-corruption and trade sanctions.
  • Airbus had complete absence of commitment to compliance.
  • Airbus had a completely broken culture.
  • What were the three categories of ITAR violation identified by the DOJ?


Mike Volkov’s review of the ITAR portion of the US enforcement action here.