Fcpa Compliance Report

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Matt Kelly and Mike Volkov provide next insight. Next week will be views from Jay Rosen and Jonathan Armstrong.    Matt Kelly opens by considering the Evaluation as a continuation in a series of pronouncements around ‘operationalizing’ your compliance program. He discusses whether this approach consistent or different with the regulatory requirements of SEC FCPA enforcement and how would this document intersect with SEC ‘regulatory enforcement’ of the FCPA? Finally, he considers whether the Evaluation ties in at all to a control environment under either the COSO 2013 Framework or COSO ERM framework. For Matt Kelly’s posts see the following:             Fresh FCPA Guidance from the Justice Department; and             Deeper Dive into new DoJ Compliance Guidance Mike Volkov discusses why the Evaluation was issued literally in the dead of night and why would t