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FCPA Compliance Report

James Koukios on the Monaco Memo

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:

  1. Issues involving individual accountability.
  2. Burden shifting on communications devices and timeliness of self-disclosing and reporting.
  3. How does the Monaco Memo lay out DOJ expectations?
  4. Monaco Memo at 30,000 ft and ground level…
  5. Tweaks to the Yates Memo formulation.
  6. New requirements to the FCPA Corporate Enforcement Policy
  7. Will the incentives be enough?

 Resources

James Koukios on MoFo

Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog

  1. A Jolt for Compliance
  2. Timely Self-Disclosure
  3. Corporate Compliance Programs
  4. Monitors
  5. Polite Speech

Monaco Memo

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FCPA Compliance Report

James Koukios on the MoFo February Int’l Anti-Corruption Newsletter

In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we consider some of the key ABC issues in the always great MoFo Monthly Top 10 International Anti-Corruption Developments for February 2022. Highlights of this podcast include:

  1. KT FCPA Resolution
  2. Roger Ng convicted at FCPA trial.

Resources

James Koukios on the MoFo website

February International Anti-Corruption Newsletter here

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FCPA Compliance Report

James Koukios on the MoFo January Int’l Anti-Corruption Newsletter


In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we consider some of the key ABC issues in the always great MoFo Monthly Top 10 International Anti-Corruption Developments for January 2022. Highlights of this podcast include:

  1. Opinion Release 22-01.
  2. Summary Judgment granted in bribery related breach of contract case-use of bribery allegations to get out of contract.
  3. FIFA defendants raise local law defense. What is it and how is it raised and why it has never been successful in a FCPA context
  4. Former CEO of Pemex charged. Is Mexico finally stepping up to ABC enforcement?
  5. South African anti-corruption commission. Will this finally help SA move past capture and a culture of corruption.

Resources
James Koukios on the MoFo website
January International Anti-Corruption Newsletter here

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FCPA Compliance Report

James Koukios on the Monaco Speech

In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we take a deep dive into the Lisa Monaco speech from October and related remarks from other DOJ representatives about the DOJ refocus on white collar enforcement and related issues. Highlights of this podcast include:

·       Who is the DAG and what does that position entail?

·       Reinstatement of Yates Memo.

·       Does this change an investigation focus?

·       The new focus on culture and how do you assess corporate culture?

·       What about reports of all violations, enforcements and even investigations even is outside FCPA?

·       What are the implications of this change?

·       How will all this work with current FCPA Corporate Enforcement Policy?

·       The revocation of Benczkowski Memo. What are the implications?

·       The new focus on monitorships?

·       What about recidivists or those who fail to meet the obligations of their DPA/NPA?

Resources

James Koukios on the MoFo website.

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FCPA Compliance Report

James Koukios on MoFo January and February Int’l ABC Newsletter


In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios, partner at Morrison & Foerster and editor of the firm’s great monthly International Anti-Corruption Developments Newsletter. In this episode we look back to some of the key developments from the January and February newsletters.
Highlights include:

  • 2021 TI-CPI released. What value do you see in it? Do compliance professionals rely too greatly on it to determine an appropriate level of due diligence?
  • Samir Khoury denied cert. How or why could an indictment go unsealed for 10 years?
  • Daniel Comoretto pleads guilty. Follow on from Sargeant Marine FCPA enforcement action.
  • KBR decision. What does it mean for the SFO?
  • Samsung Industries resolves corruption matter thru Leniency Agreement.
  • Paul Bond convicted on retrial.
  • Spain extradited Alonso Ancira to Mexico. What if any is the significance to this action?
  • Car Wash ends. How would you assess its overall impact on the global fight against bribery and corruption?

Resources 
January International Anti-Corruption Developments
February International Anti-Corruption Developments
James Koukios on MoFo

Categories
FCPA Compliance Report

James Koukios on MoFo Top 10 Int’l ABC Developments for December 2020

In the Episode, fan fav and MoFo partner James Koukios returns to discuss the firm’s always informative Top 10 International Anti-Corruption Developments for December 2020. We focus this episode on ABC enforcement efforts from other countries. Highlights include:

·       CFTC brings first FCPA enforcement action;

·       Patrick Ho conviction upheld;

·       Brazilian government announces 5-year ABC plan;

·       MPP settles Car Wash enforcement action; and

·       ABC reforms introduced in NDAA.

Recourses
MoFo Top 10 International Anti-Corruption Developments for December 2020

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FCPA Compliance Report

James Koukios on MoFo Top 10 Int’l ABC Developments for November 2020


In the Episode, fan fav and MoFo partner James Koukios returns to discuss the firm’s always informative Top 10 International Anti-Corruption Developments for November 2020. We focus this episode on ABC enforcement efforts from other countries. Highlights include

  • OECD Reports lauds US enforcement efforts and increased enforcement efforts by the Netherlands;
  • World bank debars German firm;
  • Developments in Mexico;
  • Developments in and concerning Venezuela; and
  • China and its repatriation of fugitives.

Recourses
MoFo Top 10 International Anti-Corruption Developments for November 2020

Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for March 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for March 2020.
Some of the highlights include:

  1. Portugal Freezes Assets of Africa’s Richest Woman-could this be even bigger than 1 MDB?
  2. Thoughts on Teva FCPA enforcement action in the context of it completing its DPA.
  3. What is the DOJ saying around FCPA enforcement in the Covid-19 era? (IE., any change in enforcement cadence)
  4. What significance, if any, do you see in Mexico request to extradite former Pemex official?
  5. OECD Expresses Concern over Costa Rica’s Foreign Bribery Enforcement Record. What does this mean?

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for March 2020 Newsletter click here.

Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for February 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for February 2020. Some of the highlights include:

  1. Lambert Motion for Acquittal Denied. We take a deep dive into the motion and the court’s ruling.
  2. Pemex Investigation Expands. What does it mean for US companies?
  3. Is each email a separate FCPA violation? What does this mean for the DOJ going forward?
  4. Cardinal Health FCPA resolution. Key takeaways for the compliance professional.

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for February 2020 Newsletter click here.

Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for January 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for January 2020. Some of the highlights include:

  1. Airbus-in this massive and sprawling case, Koukios details what are the 3 key takeaways you would advise a company on from the matter.
  2. The French PNF involvement and what it might mean from French anti-corruption enforcement going forward.
  3. SFO Wins First Conviction for Withholding Documents Requested in Bribery Investigation.
  4. Isabel dos Santos, Sonangol and Angola-what does it mean and what should companies do now?

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for January 2020 Newsletter click here.