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