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Alex Cotoia, Regulatory Manager at The Volkov Law Group, recently was featured on Tom Fox's Diligent Podcast Series focused on Third-Party Risk Management. The Podcast is available HERE. In 2022, the overwhelming majority of FCPA related enforcement actions involved third parties and required organizations to reprioritize third
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The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement. At the same time, DOJ announced significant new compliance program expectations, and appeared ready to press forward with a number of FCPA resolutions. The Numbers For the year, DOJ
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The ABB case, like most significant FCPA enforcement actions, sets important precedent and policy reminders. With time, and looking back, ABB gives companies with a prior criminal history a way forward to seek a fair resolution notwithstanding huge obstacles based on past performance. If you are ABB, you dodged a