The J&F FCPA Enforcement Action

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. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are:  It was one of the most bold, audacious bribery schemes ever. Follow on from Brazil’s largest anti-corruption enforcement action, JBS. What happens when an acquirer of a US listed company is the corrupt entity? Is a target required to perform due diligence on the source of the money used in a M&A deal? Did Pilgrim’s Pride have any responsibility? Are there any US individuals involved? Is Pilgrim’s Pride a victim, entitled to compensation?  Resources See Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCA See Tom’s exploration the FCPA Compliance and Ethics Blog Part 1-Introduction Part 2-The Bribery Schemes Part 3-The SEC Order Part 4-The Plea Agreement Learn more about your ad choices. Visit megaphone.fm/adchoices