Questions - FCPA

Questions - FCPA


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And it might just be worth here, we've had a couple of questions come through, just to spend a couple of seconds here going through those questions. One in particular that I'm interested to learn a little bit more about which is, Paul, directionally where do you see the FCPA going under the new administration, the Trump administration. Do you think it's going to stay the same, change, what are your thoughts on that?

Well I think it's kind of ... Trump has had a lot on the plate lately, and I know one of his priority as a candidate was clearly to get to regulation and see the impact that certain regulations, mainly around Dodd-Frank I think he was talking about, but in this particular regulation itself, I would think that the DOJ and SEC will continue to root out bad behaviors and bad actors in this regulation. I think probably even more so now given Washington speaks of Russian interference and all of that into some about politics. I think it even becomes even more important now with respect to any type of foreign entity, that they are vigilant. So I expect SEC and the DOJ to be very aggressive. I don't think they're going to pull back. I expect that the trend line that I showed will continue to peak, and as I said it's early on in 2016, but I certainly expect to see some cases coming across, if not necessarily in financial services, but overall, but I expect both.

Okay and just finally here, a good question, who in the organization is best to deal with FCPA issues? Who takes ownership if it's not the Chief Compliance Officer? What are your thoughts on that?

Yeah so obviously since it's a regulatory rule, and it is a part of the firm's or should be a part of the firm's written policy, I would think the first line of defense would be the CCO, but having said that because of the fines that can be imposed, I think a large piece of it will probably fall on your internal council as well, but what I want to impress here to the audience is that really everyone has ownership of FCPA. There is no one that is immune from being fined, sanctioned or jail time, dependent upon bribery or corruption that may go on in the organization. [inaudible 00:42:32] important. That's why monitoring activities through technology and otherwise is key. I really feel everyone should have ownership for this rule.


This webinar was co-hosted with MCG Consulting


Read our blog post: FCPA Fines in 2016 - Summary


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