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 the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are:

Why were the facts so egregious?
How high up in the organization did the corruption scheme go?
Why was the Board’s performance so abysmal?
Was the head of Internal Audit in on the bribery scheme?
What was the role of short-sellers in bringing this massive fraud to light?

Resources

See Matt’s blog posts on Radical Compliance

Herbalife Pays $123M on FCPA Charges

See Tom’s 3-part blog post series on the FCPA Compliance and Ethics Blog

The Herbalife FCPA Enforcement Action, Part 1

The Herbalife FCPA Enforcement Action, Part 2

The Herbalife FCPA Enforcement Action, Part 3

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