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, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include:

· What are clawbacks and how would they work in practice?

· Does a lack of corporate clawbacks lead to aggravating factors?

· How much credit will a company receive by instituting clawbacks?

· CCO certifications are here to stay.

· How does the Polite Speech relate to the Monaco Memo.

Resources

Matt in Radical Compliance

Text of Polite Speech

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