Menu4/19/16: There’s something oddly comforting that two respected compliance authorities can disagree on the impact and value of a DOJ program or guidance. The program is DOJ’s recently released FCPA Enforcement Plan and Guidance, which references a pilot program. The authorities are Michael Volkov, well known for his Corruption, Crime and Compliance Blog, and Tom Fox, equally well known for his blog FCPA Compliance and Ethics. Actually, there are more dissenting authorities, all with links in the bottom two posts. The links are worthwhile, too, but the post by Volkov and Fox are a first step in understanding the different opinions about what DOJ’s enforcement strategy and pilot program mean for compliance professionals.
