The J&F FCPA Enforcement Action


Manage episode 274953816 series 2783374
By Tom Fox. Discovered by Player FM and our community — copyright is owned by the publisher, not Player FM, and audio is streamed directly from their servers. Hit the Subscribe button to track updates in Player FM, or paste the feed URL into other podcast apps.

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?


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

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162 episodes