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Compliance Into the Weeds

Happy Hour FCPA Enforcement Action Involving ENI


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 podcast Matt Kelly and Tom Fox take a deep dive into the recently released SEC enforcement action against ENI involving FCPA violations, which was released just before 5 PM on Friday April 17.
Some of the highlights include:

  • What were the background facts?
  • What is the standard a parent has over a subsidiary for FCPA violations?
  • What were the internal controls violations?
  • What were the books and records violations?
  • What are the lessons learned for the compliance professional?
  • Did the fact that ENI was a recidivist make any difference?

Resources
Matt Kelly blog post, ENI Settles FCPA Case for $24.5 Million
Tom Fox blog post,  Recidivist ENI