
We talked about:
- the FCPA charges brought by the SEC and DOJ against Albemarle in 2023;
- sales agents, internal controls and third-party risk in sales transactions;
- the cooperation credit afforded Albemarle and what got them a steep penalty discount;
- self-reporting, cooperating and remediating a compliance program in practice under a revised Corporate Enforcement Policy at the DOJ;
- the DOJ’s new white-collar crime enforcement priority list and revisions to its Whistleblower Pilot Program;
- his advice on navigating a shifting regulatory landscape and uncertainty; and
- possible AI use cases in ethics and compliance programs and using data analytics in compliance program oversight.
A transcript of the podcast is available here.