Revisiting the DOJ’s “Monaco Memo”
Release Date:
Dan Kahn, former Chief of the FCPA Unit, joins the podcast to discuss the September Monaco Memo now that the compliance community has had some time to debate it. Dan discusses the good news, and some concerns, associated with cooperation credit, voluntary disclosure, recidivist companies, monitors and ongoing concerns about personal devices and ephemeral apps.
Revisiting the DOJ’s “Monaco Memo”