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. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms.
Some of the issues we consider are:
· Are DPAs and NPAs simply the cost of doing business?
· Is the Wells Fargo growth cap a valid model?
· What about greater DOJ or Monitor oversight?
· Longer terms for DPAs?
· New enforcement tools coming?
· New review of DPAs and NPAs.
Resources
Matt in Radical Compliance
So What Happens Next with DPAs
Tom in the FCPA Compliance and Ethics Blog
Monaco Speech - Individual Accountability
Monaco Speech - Monitors
Text of DAG Monaco Speech
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