Tag: FCPA

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ACI FCPA Conference 2025

ACI FCPA and Global Anti-Corruption Conference 2026 Speaker Preview Podcast Series: Cartels, TCOs and the New Corruption Risk Landscape

In this episode of the FCPA and Global Anti-Corruption Conference 2026 Speaker Preview Podcast series, we discuss the panel, “Cartels, TCOs, and the New Corruption Risk Landscape: Rethinking Corporate Compliance in an Era of Evolving Threats.” Some of the issues discussed in this podcast and the panel presentation are:

  • The panel features Didier Lavion, Gerald Moody, John Richter, and Clayton Solomon and is moderated by Veronica Yepez.
  • How the Administration’s focus on cartels and TCOs is reshaping corruption risks and assessments.
  • How to distinguish between corruption red flags and cartel/TCO and FTO risks.

As global enforcement priorities shift and anti-corruption risks grow more complex, staying ahead requires direct insight from those shaping, interpreting, and navigating the regulatory landscape.

Returning to Washington, DC, this December 10-11, ACI’s flagship FCPA and Global Anti-Corruption Conference brings together an unparalleled gathering of government enforcement officials, in-house compliance leaders, and top legal practitioners from around the world. Gain firsthand insights, benchmark strategies with industry peers, and walk away with practical approaches to strengthen compliance programs, manage emerging risks, and prepare for what’s next. Few events offer this depth of expertise, access, and opportunity to connect with the global anti-corruption community.

I hope you can join us. For event details, click ⁠here⁠. As an extra benefit to podcast listeners, ACI is offering a 10% discount on the ⁠registration⁠ price. Use discount code D10-999-CPN27 to apply your discount.

The Compliance Podcast Network produces the ACI FCPA and Global Anti-Corruption Conference 2026 Speaker Preview Podcast series. ACI sponsors this series.

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ACI FCPA Conference 2025

ACI FCPA and Global Anti-Corruption Conference 2026 Speaker Preview Podcast Series, Investigations in High Risk and High-Complexity Jurisdictions

In this episode of the FCPA and Global Anti-Corruption Conference 2026 Speaker Preview Podcast series, we discuss an upcoming panel: “Investigating Corruption in High-Risk and High-Complexity Jurisdictions: Navigating Data Restrictions, Beneficial Ownership Challenges, and Cross-Border Cooperation.”

The session features an expert faculty line-up, including Ben Curtis (Partner at McDermott Will & Schulte LLP), Daniel Meyers (President of Consulting & Information Governance at TransPerfect), and Maya Song (Partner at Ropes & Gray LLP).

Some of the key issues explored in this podcast and upcoming panel presentation include:

  • High-Risk vs. High-Complexity: Why compliance teams routinely plan for high-risk jurisdictions but rarely adapt their frameworks for High-Complexity markets where local transparency is severely limited.
  • Cross-Border Navigation: Practical strategies to successfully navigate strict data privacy barriers, decipher ultimate beneficial ownership (UBO) structures, and maintain safe visibility alongside international partners during a multi-jurisdictional investigation.

As global enforcement priorities shift and anti-corruption risks grow more complex, staying ahead requires direct insight from those shaping, interpreting, and navigating the regulatory landscape.

Returning to Washington, DC, this December 10-11, ACI’s flagship FCPA and Global Anti-Corruption Conference brings together an unparalleled gathering of government enforcement officials, in-house compliance leaders, and top legal practitioners from around the world. Gain firsthand insights, benchmark strategies with industry peers, and walk away with practical approaches to strengthen compliance programs, manage emerging risks, and prepare for what’s next. Few events offer this depth of expertise, access, and opportunity to connect with the global anti-corruption community.

I hope you can join us. For event details, click ⁠here⁠. As an extra benefit to podcast listeners, ACI is offering a 10% discount on the ⁠registration⁠ price. Use discount code D10-999-CPN27 to apply your discount.

The Compliance Podcast Network produces the ACI FCPA and Global Anti-Corruption Conference 2026 Speaker Preview Podcast series. ACI sponsors this series.

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FCPA Compliance Report

FCPA Compliance Report: Voluntary Disclosure In 2026: Risk, Reward, And Uncertainty

In this episode, Tom Fox cross-posted an ACI webinar he moderated on voluntary self-disclosure. He was joined by James Tillen, Dr. Hemma Lomax, and Daniel Sibille, each bringing a distinct but complementary perspective on voluntary self-disclosure and DOJ corporate enforcement strategy. This topic and others will be discussed at the ACI National FCPA and Global Anti-Corruption Conference on December 10-11 in Washington, DC.

What do our panelists see? James Tillen, a longtime FCPA and anti-corruption counselor, sees DOJ’s policy as more generous and clearer on paper but still highly fact-specific because discretion remains around timing, cooperation, and aggravating factors. Dr. Hemma Lomax, drawing on her years at the SEC and now in-house experience, similarly believes DOJ has made the rewards of disclosure more predictable while leaving real uncertainty about whether a company will qualify. Daniel Sibille adds the company-side and government-side context, respectively, emphasizing that disclosure can strengthen compliance, shape the narrative early, and improve outcomes, even as DOJ’s approach still involves judgment, discretion, and cross-border risk.

Key highlights:

  • DOJ declinations and near-miss disclosure incentives 2026
  • Timely disclosure, robust remediation, and good-faith narrative
  • Fact-Specific Race Against the Disclosure Clock
  • Early high-risk signals for defensible good faith
  • Independent assessment and formal recommendation by counsel
  • Declinations still trigger foreign and parallel financial fallout
  • Cartel Risk and DOJ Enforcement Priorities
  • Disclosing Foreign Subsidies for Declination or NPA

I hope you can join us for the ACI FCPA and Global Anti-Corruption Conference in Washington, DC, on December 10-11. For event details, click ⁠here⁠. Podcast listeners will receive a 10% discount on the registration price. Use discount code D10-999-CPN27 to apply your discount.

Resources:

Tom Fox

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LinkedIn

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

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Daily Compliance News

Daily Compliance News: November 5, 2026, The Post-Election Wrap-up Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we cover four stories from the business world, compliance, ethics, risk management, leadership, or general interest for compliance professionals.

Top stories include:

  • Corruption investigations in Washington
  • Anti-corruption legislation and enforcement
  • AI regulation and Data Center moratoriums
  • Administration Staffing
  • Prediction Markets

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

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Compliance Into the Weeds

Compliance into the Weeds: Emergency Podcast on Election Results

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds!

In this special episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the 2026 election results and what they may mean for compliance.

Key highlights:

  • Corruption investigations in Washington
  • Anti-corruption legislation and enforcement
  • AI regulation and Data Center moratoriums
  • Administration Staffing
  • State AGs and Business Courts in Texas
  • Prediction Markets
  • Supreme Court

 Resources:

Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence.

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Red Flags Rising

Red Flags Rising: S01 E46: “Knowledge” Masterclass

Mike Huneke and Brent Carlson revisit and synthesize in one episode everything trade compliance teams need to know about the “knowledge” standard under the US Export Administration Regulations (EAR).

After starting the episode with Brent’s own journey in website design and announcing free resource materials (now) available at www.redflagsrising.com (01:05), Mike and Brent specifically discuss the full definition of “knowledge” under the EAR, including its three-tiered definition of actual knowledge, reason to know, and an awareness of a high probability (08:36); the “collective knowledge doctrine” under US law (14:14); parallels to US Foreign Corrupt Practices Act (FCPA) enforcement (15:06); misperceptions regarding the Bureau of Industry & Security’s KYC Guidance (16:25); other common misunderstandings (18:11); where KYC screening programs go wrong (24:23); the limited application of the “legally distinct” rule under the Entity List catch-all (25:33); why we accepted self-certifications when national security was served by global integration (26:36); the suspended BIS Affiliates Rule and its core problems (30:43); entity-shifting (34:10); risks associated with distributors and resellers (35:10); and the potential restrictions on remote access (40:49). They then conclude with this episode’s installment of Brent Carlson’s “Managing Up” segment (46:22).

Brent’s improved website and free resources

“Knowledge”

General Prohibition 10 

Brent Carlson, When Loopholes Create Liability Pitfalls (Aug. 25, 2023)

Contact Brent

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Connect with Brent on LinkedIn

Contact Mike

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FCPA Compliance Report

FCPA Compliance Report: From Prosecutor to White Collar Lawyer to CCO and Back: Mike Koenig

In this episode, Tom Fox welcomes Mike Koenig to talk about his career and his recent move back to private practice after a 5-year stint at JBS. Mike is one of the few folks to move from private practice to an in-house CCO role, then back to private practice.

Mike began by reviewing his career, from 25 years in private practice and a 2003 DOJ Fraud Section stint prosecuting corporate fraud to becoming chief compliance officer at JBS in August 2021 amid DOJ and SEC settlement agreements requiring an effective compliance program. He describes learning to operate within business-driven priorities by building relationships, learning the business and culture, “educating not dictating,” and securing C-suite, board, and audit committee buy-in, including CEO-driven training completion. He explains that he uses trusted outside experts and focuses on the specific problem to solve rather than “boiling the ocean.” After JBS completed the settlements and listed on the NYSE in June 2025, he returned to private practice at Friedman Kaplan to advise on investigations and compliance, emphasizing concise, solution-oriented counsel. He warns against de-prioritizing compliance despite reduced enforcement, urges risk assessments (tariffs, export controls, and human rights), and recommends using DOJ compliance guidance to review programs.

Key highlights:

  • Career Journey Recap
  • Joining JBS In-House
  • Building Compliance Fast
  • Relationships Not Dictates
  • Leadership Buy-In
  • FCPA Pause or a Wake-Up Call
  • Compliance Through 2030

Resources:

Mike Koenig on LinkedIn

Mike Koenig at Friedman Kaplan

Friedman Kaplan

Tom Fox

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Facebook

YouTube

Twitter

LinkedIn

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

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Daily Compliance News

Daily Compliance News: August 31, 2026, The Oops, Just Kidding Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • $50MM and a DPA in FIFA FCPA case.(Law360)
  • Trump Administration blacklisting of Anthropic ruled illegal. (WSJ)
  • US corp intelligence firm withdraws claim against trader. (FT)
  • What is really behind Xi’s ABC campaign? (SCMP)

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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Daily Compliance News

Daily Compliance News: August 28, 2026, The Bill Gates Warns on AI Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Ex-Corsa Coal exec files appellate brief. (Law360)
  • California AG goes after Paramount. (WSJ)
  • Bill Gates warns on AI. (NYT)
  • More trouble for Malaysia ex-PM. (SCMP)

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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Compliance Into the Weeds

Compliance into the Weeds: Compliance Implications of DOJ’s New Fraud Division and McDonald Memo

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them in greater depth and uncover hard-hitting insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ’s “McDonald Memo.”

This DOJ Memo outlines a new Trump administration fraud division that broadly claims jurisdiction over “all types of fraud,” potentially reshaping DOJ enforcement and creating uncertainty about overlapping authority with existing divisions (e.g., antitrust). They review five priority areas: a. public trust/financial integrity fraud (procurement, bid rigging, grants, social welfare), b. healthcare fraud, c. internal revenue fraud, d. global trade and commerce fraud (tariffs/customs), and e. an undefined “corporate misconduct” category. From a compliance perspective, they urge companies to reassess risk areas (healthcare, importers, and government contractors), strengthen third-party oversight and documentation, and “pressure test” compliance programs with transparency and recordkeeping. They also warn that politicized enforcement and unclear guidance—such as on cartel-related liability—complicate compliance strategy and may tempt leaders to treat settlements as a cost of doing business.

Key highlights:

  • McDonald Memo Overview
  • Fraud Division Scope and Uncertainty
  • Five Fraud Categories Explained
  • Corporate Misconduct Questions
  • Compliance Program Impacts
  • Documentation as Defense
  • Mexico Cartels and Strict Liability

Resources

Matt in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.