This episode of the FCPA Compliance Report begins a special two-part series with two well-known compliance professionals. Matt Galvin, most recently the CCO at AB-InBev, and Dan Kahn, former acting Deputy Assistant Attorney General of the Criminal Division, Chief of the Fraud Section, and Chief of the FCPA Unit. Dan is now in private practice at DavisPolk.
In this Part 1, we take up the key issues around dealing with the DOJ, including the factors which go into the decision to self-disclose, incentives and disincentives in compliance programs, internal investigations including who is involved and scoping an investigation, presenting information to the DOJ during the pendency of an investigation and negotiating the final settlement and post-resolution; including both ongoing reporting and continuing innovation in your compliance program.
Resources
Matt Galvin on LinkedIn - https://bit.ly/3xk8GJ2
Dan Kahn at Davis Polk - https://bit.ly/3Ef9e4p
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