Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, we begin a short podcast series on the Albemarle FCPA enforcement action. Today, we have Karen Moore on the internal controls failures and other areas identified in the SEC enforcement action.
The recent FCPA enforcement action against Albemarle has sparked a lively debate in the compliance community, particularly regarding the company’s internal controls, imposed penalties, and the lack of monitorship. While Karen is surprised at this development, Tom believes it is consistent with the new DOJ FCPA policy.
One of the key takeaways from the episode is the importance of thorough due diligence and stronger measures to prevent corruption. The case highlights the need for compliance officers to operate beyond their comfort zones and ensure that the right people receive the right training to spot issues. It also raises questions about the credibility of messages about risk tolerance from senior leadership and the effectiveness of deal reviews. Join us as we dive deeply into these issues in this FCPA Compliance Report podcast episode.
Key Highlights:
- Albemarle’s Penalties
- Identifying Red Flags in Due Diligence
- Including Monitors in Plea Deals for Compliance
Resources:
Tom Fox blog post series on the Albemarle FCPA Enforcement Action.
Tom Fox
