In this Episode of the FCPA Compliance Report, I visit with Miller & Chevalier members John Davis and James Tillen. We take a deep dive into the WPP Foreign Corrupt Practices Act enforcement action. Highlights of this podcast include:

  1. What the basic facts?
  2. What were the missed red flags and M&A failures?
  3. When do compliance incentives become perverse?
  4. What were the investigative failures?
  5. What made the Chinese bribery scheme so unusual?
  1. The Peru bribery scheme was across national lines. Does that make it harder to detect?
  1. Where is the DOJ?
  2. Where is the SFO?
  3. How did WPP get a resolution with no monitor?


John Davis

James Tillen