How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo lay out the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a full declination. All of the actions you can take come from recent DOJ prosecutions under the FCPA and speeches from DOJ representatives. This podcast, sponsored by Ethico, is the companion series to the book The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action. Today, we discuss lesson number 10, your investigation process.
Tom and Nick discuss the importance of establishing a culture where employees feel empowered to speak up, the process of triaging and conducting internal investigations, and the significance of these practices in modern compliance programs. They reflect on the shift in workforce mentality towards valuing integrity and the practical implications for ethics and compliance teams in today’s knowledge economy. They emphasize the necessity of effective internal reporting mechanisms and middle management’s strategic role in capturing risk intelligence. The conversation explores the challenges and opportunities in optimizing compliance processes to mitigate risks and demonstrate organizational effectiveness to regulators like the DOJ and SEC.
Key Highlights and Issues
- The Importance of Speak Up Culture
- Workforce Dynamics and Compliance
- Challenges in Compliance Reporting
- Whistleblower Programs and Internal Reporting
- Optimizing Compliance Processes
Resources:
Nick Gallo on LinkedIn
The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action
Tom
