The podcast dives into the evolving landscape of FCPA enforcement, with a significant rise in penalties and a focus on individual prosecutions. Key cases featuring major corporations like Raytheon and SAP are discussed, alongside the DOJ's new whistleblower program. Emerging technologies, particularly AI, pose new compliance challenges. The return of traditional bribery tactics like travel and gifts raises questions about corporate ethics. Amidst this, updates on compliance initiatives signal a shift in how companies approach legal obligations.
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insights INSIGHT
2024 FCPA Enforcement Overview
2024 was a moderate FCPA enforcement year, but penalties significantly increased.
Key enforcement actions emphasize the importance of robust compliance strategies.
insights INSIGHT
Key FCPA Cases of 2024
DOJ prosecuted eight entities, including major companies like SAP, Gunvor, and Raytheon.
The SEC focused on five entities and four individuals, highlighting a continued emphasis on individual accountability.
question_answer ANECDOTE
Gunvor Case
Gunvor paid $661 million in a top 10 FCPA case, involving a decade of bribery in Ecuador.
Despite not self-disclosing, Gunvor received a 25% discount, raising questions about DOJ's leniency.
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Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025? Will the push for innovation in corporate compliance programs be enough to maintain momentum, especially with emerging technologies like artificial intelligence? In this episode of Corruption, Crime and Compliance, Michael Volkov dives deep into the FCPA enforcement landscape of 2024, outlining key cases, changes in DOJ policies, and the evolving role of compliance programs. He highlights the significant rise in penalties and individual criminal prosecutions, as well as the continuation of major corporate settlements such as Raytheon, Trafigura, Gunvor, and SAP. The episode also explores DOJ's new whistleblower program and its continued push for companies to enhance their compliance frameworks.
You'll hear him discuss:
Key FCPA enforcement matters in 2024 including the Raytheon, Trafigura, Gunvor, and SAP cases.
The shift in DOJ’s approach, where individual prosecutions now play a larger role than ever before.
The rise in penalties: 2024 saw a significant jump, with a total of $1.7 billion in fines.
The return of travel, hospitality, and gifts as common bribery techniques, despite increased focus on compliance.
DOJ's major industry sweeps, particularly targeting the energy commodity trading industry.
The emergence of new compliance challenges with a focus on artificial intelligence and emerging technologies in corporate settings.
The controversial SAP settlement and the DOJ’s approach to a lack of voluntary disclosure.
The impact of mergers and acquisitions on compliance processes and the integration of acquired companies.
DOJ’s new whistleblower program designed to incentivize individuals to report misconduct.
How companies should approach merger and acquisition integration to ensure compliance and prevent risks.
Corruption Crime & Compliance