Corrupt Culture and Bags of Cash-the KT Corp. FCPA Enforcement Action

February 23, 2022

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. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider

Background facts and a corrupt culture, literally from the top.
How does the SEC have jurisdiction over KT Corp?
Why you need a flow chart of the bribery schemes and a scorecard of the players.
Corruption leading to the Korean Blue House.
Bags of cash delivered and kept in office safes.
Was the resolution an interim step before a monitor is employed?

Resources
Tom with a 3-part series in the FCPA Compliance and Ethics Blog
Matt in Radical Compliance