Categories
FCPA Compliance Report

Jonathan Armstrong on Herbalife from a UK Perspective


In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this concluding Part 5, I am joined by Jonathan Armstrong and we discuss the enforcement action from the UK perspective under the UK Bribery Act.
Some of the highlights include:

  • China is a known high-risk business venue.
  • Licenses are required in China for direct sales.
  • UK Bribery Act not as concerned with the blurring of public and private officials.
  • Scottish cases provide some interesting analogies.
Categories
This Week in FCPA

Episode 225 – the I Beat Covid edition


As President Trump claims to be ‘Covid-free’ and the (non-cheating) Houston Astros prepare to return to the ALCS, Tom and Jay are back to look at top compliance articles and stories which caught their eye this week.

  1. JPMorgan pays $920 million fine for spooking. Matt Kelly looks at it in Radical Compalince. Tom and Matt take a deep dive in Compliance into the Weeds. Mike Volkov considers on Corruption Crime and Compliance.
  2. What is ‘efficient patent infringement’ (sort of like being ‘just a little bit’ pregnant)? Jon Rusch in Dipping Through Geometries.
  3. Of donut holes and cyber attacks. Jonathan Marks in Board and Fraud.
  4. What is effective discipline? Jeff Kaplan in CEP Magazine.
  5. Is the SEC moving to increase its penalties in light of Lui? Robert Cohen and Stefani Johnson Myrick in NYU’s Compliance and Enforcement Blog.
  6. Mobile devices and internal investigations. David Carns in CCI.
  7. What is a Grand Jury subpoena? Sara Kropf in Grand Jury Target.
  8. The Everything Complaince gang takes a dive into the Herbalife FCPA resolution. Monday-Mike Volkov on what he would have done; Tuesday-Jay Rosen on the lack of a monitorship; Wednesday-Matt Kelly on the role of Internal Audit; Thursday-Jonathan Marks on the role of gatekeepers; Friday-Jonathan Armstrong on the UK perspective.
  9. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, we continue our exploration of compliance for Business Ventures.  Monday-Dis-linking illegal conduct; Tuesday-JV Risks Under the FCPA; Wednesday– JV Due Diligence; Thursday-Compliance T&C’s in JV agreements; Friday-Auditing JVs .Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
  10. Join Tom (and Matt Kelly) for Home Stretch 2020, a webinar sponsored by Complaince Line. Check at the agenda and register here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

Categories
Daily Compliance News

October 9, 2020-the Increased Compliance Risks edition


In today’s edition of Daily Compliance News:

  • Covid has increased compliance risks. (WSJ)
  • Trump NLRB accuses Google contractor of illegal anti-union activity. (NYT)
  • OSHA to workers on Covid-TS baby. (WaPo)
  • Trump ally, who worked for Jho Low, pleads guilty. (WSJ)