Compliance into the Weeds: Carrots and Sticks in Washington: Antitrust Whistleblowers and an FCPA SOL Extension

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at two recent developments sending a common message to compliance teams.

First, DOJ antitrust official Daniel Glad warns that a new Antitrust Whistleblower Awards program and increased pursuit of prison time for individuals compress companies’ timelines to investigate and self-disclose, because insiders may report first and cost those firms potential leniency. Second, Senate Democrats, led by Elizabeth Warren, propose the FCPA Reinforcement Act to extend the FCPA statute of limitations from five to 10 years, creating an eight-year window, with the aim of preserving future enforcement capacity for misconduct occurring now. They connect these “sticks” with “carrots,” such as fast declinations for self-disclosure, emphasizing the need for robust compliance programs, a strong reporting culture, prompt investigations, and clear decisions on disclosure, regardless of who controls Washington.

Key highlights:

  • Two Washington Signals
  • Antitrust Whistleblower Push
  • FCPA Reinforcement Act
  • Carrots, Sticks, and Culture
  • Why Internal Reporting Matters
  • Self Disclosure Through Line

Resources:

Matt in Radical Compliance here and here

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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