Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we have a special live and in person podcast recording from Converge19. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Quad/Graphics and its Peruvian subsidiary. Matt comes in smoking on the egregious conduct of the company and the lack of criminal sanctions against the company.

Some of the highlights include:

  • How did the company garner credit for prompt disclosure when it knew about the conduct for 3 years?
  • Why have there been no criminal indictments against individuals?
  • How many sham vendors, invoices and payments does a company need to take notice?
  • Where was compliance?
  • Why is it the sham-ness of it all?

For additional reading see the following:

Matt’s blog post, Graphics Firm Draws $10 FCPA Settlement, on Radical Compliance.

Tom’s blog post, Quad/Graphics-the Sham-ness of it all, on the FCPA Compliance Report.