The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject. In this episode, Matt Kelly and I consider the ABB Foreign Corrupt Practices Act resolution, deep dive into the case, and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) See more +
The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject. In this episode, Matt Kelly and I consider the ABB Foreign Corrupt Practices Act resolution, deep dive into the case, and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) certification?
Some of the highlights included:
1. The background facts.
2. The corrupt supplier's ABB used to facilitate their bribery and corruption.
3. The convoluted self-disclosure in this matter. (Should they have used Twitter with the notation #committedbribery?)
4. What constituted extraordinary cooperation during the pendency of the investigation?
5. What are the implications of real-time sharing during an investigation?
6. What were the steps which demonstrated the exception remediation?
7. A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out?
8. Did the DOJ change its policy from mandatory CCO certification to discretionary?
Tune in to the Compliance Into The Weeds podcast to learn more about ABB FCPA Resolution. #CITW #Compliance #ABB #FCPA #CPN #Podcast See less -
