The WPP Foreign Corrupt Practices Act 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. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP. Some of the issues we consider are: Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture? What is the role of compliance in M&A? When does a financial incentive become perverse? Where is the DOJ? Where is the SFO? How did WPP avoid a monitor?  Resources Matt in Radical Compliance WPP Pays $19M on FCPA: An Analysis  Tom in the FCPA Compliance and Ethics Blog Part 1-Background Part 2-Structural Compliance Deficiencies Part 3-Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices