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 episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are:

  • It was one of the most bold, audacious bribery schemes ever.
  • Follow on from Brazil’s largest anti-corruption enforcement action, JBS.
  • What happens when an acquirer of a US listed company is the corrupt entity?
  • Is a target required to perform due diligence on the source of the money used in a M&A deal?
  • Did Pilgrim’s Pride have any responsibility?
  • Are there any US individuals involved?
  • Is Pilgrim’s Pride a victim, entitled to compensation?


See Matt’s blog posts on Radical ComplianceJBS, Internal Controls and the FPCA

See Tom’s exploration the FCPA Compliance and Ethics Blog

Part 1-Introduction

Part 2-The Bribery Schemes

Part 3-The SEC Order

Part 4-The Plea Agreement