Episode 108 - the ABB Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. Everything Compliance which has been honored by W3 as a top talk show in podcasting. In this episode, we have the quintet of Jay Rosen, Jonathan Armstrong, Karen Woody, Tom Fox and Matt Kelly on the ABB FCPA Enforcement action. We conclude with our fan fav Shout Outs and Rants section.

1. Matt Kelly looks at the enforcement action from the CCO certification perspective. He has his first recidivist rant by ending the year with a rant about the person he started the year ranting about, Elon Musk. This time it was for the Thursday Night Massacre.

2. Karen Woody looks at the case from the perspective on internal control failures and overrides. She shouts out to Stephen Twitchboss for his music and influence on popular culture.   

3. Tom Fox discusses how the DOJ thread a tight needle by rewarding ABB for its attempt to self-disclose, extraordinary cooperation and remediation by not requiring a monitor and giving a discount even through ABB is the first time three-peat offender under the FCPA. He shouts out to Christine McVie, singer and songwriter for Fleetwood Mac who recently passed away. 

4. Jonathan Armstrong considers the ABB enforcement action from the UK perspective and opines how a UK judge might consider the company’s recidivism differently than the DOJ did. He rants about ongoing tech scams. 

5. Jay Rosen reviews the enforcement action from the perspective of how the bribes were funded. He shouts out to Mike Gabler, winner of Season 43 of Survivor who donated his $1MM winnings to help veterans. 

The members of the Everything Compliance are:

•       Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com

•       Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu

•       Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com

•       Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com

•       Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at jonathan.marks@bakertilly.com

The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network. 

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