In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this Part 4, Jonathan Marks and Tom Fox discuss the role of gatekeepers and the lack of skepticism at the Board of Directors.
Some of the highlights include:

• Chief Audit Executive and Chief Compliance Officer exits should be 8K events.
• Who guards the gatekeepers?
• The Board is responsible for management override of controls.
• Why was there a lack of skepticism at the Board level?