The WPP Foreign Corrupt Practices Act Enforcement Action

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. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP.

Some of the issues we consider are:

• Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture?
• What is the role of compliance in M&A?
• When does a financial incentive become perverse?
• Where is the DOJ? Where is the SFO?
• How did WPP avoid a monitor? 

Resources

Matt in Radical Compliance

WPP Pays $19M on FCPA: An Analysis

 Tom in the FCPA Compliance and Ethics Blog

Part 1-Background

Part 2-Structural Compliance Deficiencies

Part 3-Bribery Schemes

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