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. In this episode Matt and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are:
- Why were the facts so egregious?
- How high up in the organization did the corruption scheme go?
- Why was the Board’s performance so abysmal?
- Was the head of Internal Audit in on the bribery scheme?
- What was the role of short-sellers in bringing this massive fraud to light?
Resources
See Matt’s blog posts on Radical Compliance
Herbalife Pays $123M on FCPA Charges
See Tom’s 3-part blog post series on the FCPA Compliance and Ethics Blog
The Herbalife FCPA Enforcement Action, Part 1
The Herbalife FCPA Enforcement Action, Part 2
The Herbalife FCPA Enforcement Action, Part 3
