In this special 5 part podcast series, I am taking a deep five into the Monaco Memo and analyzing it from a variety of angles. In this episode of the FCPA Compliance Report, I am joined by fan-fav James Koukios, a partner at MoFo. James is a former member of the FCPA Unit, and in this podcast, we take a deep dive into the Monaco Memo. Some of the highlights include:
- Issues involving individual accountability.
- Burden shifting on communications devices and timeliness of self-disclosing and reporting.
- How does the Monaco Memo lay out DOJ expectations?
- Monaco Memo at 30,000 ft and ground level…
- Tweaks to the Yates Memo formulation.
- New requirements to the FCPA Corporate Enforcement Policy
- Will the incentives be enough?
Resources
James Koukios on MoFo
Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog
- A Jolt for Compliance
- Timely Self-Disclosure
- Corporate Compliance Programs
- Monitors
- Polite Speech
