Former Enforcement Officials Reflect on the Last Decade of Anti-Bribery Enforcement and its Future
Bribe, Swindle or Steal
Alexandra Addison-Wrage of TRACE International
4.9 • 582 Ratings
🗓️ 17 April 2024
⏱️ 44 minutes
🧾️ Download transcript
Summary
This week on Bribe, Swindle, or Steal, we listen in on the lively presentation at the 2024 TRACE Forum featuring former enforcement officials, Charles Duross, Partner, Morrison Foerster, David Last, Partner, Cleary Gottlieb, and Mark Mendelsohn, Partner, Paul Weiss. Speaking with TRACE President, Alexandra Wrage, Chuck, David, and Mark discuss their time as Chiefs of the FCPA Unit and their experiences navigating heightened scrutiny and shifting resources, and then they offer their perspectives on what lies ahead.
Transcript
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| 0:00.0 | Welcome back to the podcast, bribe, swindle, or steel. |
| 0:10.1 | I'm Alexandra Rogge, and for this week's podcast, we have a really fun and unique opportunity |
| 0:14.7 | to hear from three former chiefs of the FCPA unit. |
| 0:18.7 | Mark Mendelssohn, now with Paul Weiss, Chuck DeRoss with Morrison Forrester, |
| 0:23.2 | David Last, with Cleary Gottlieb. At the trace forum in Annapolis last month, they talked about how |
| 0:28.1 | enforcement has changed over the last two decades. They made predictions about the year ahead, |
| 0:33.0 | and then they described their best days on the job and worst days on the job. Here they are. |
| 0:37.8 | Mark, I'm going to start with you. How has FCPA enforcement changed since your day? |
| 0:44.8 | I was trying to think of the best way to answer this question. So I've got four kids. Two of them |
| 0:50.7 | are teenagers slash long adults. Two of them are in the toddler phase. |
| 0:56.7 | And the best analogy I could come up with is that I think FCPA enforcement was in its |
| 1:03.0 | toddler stage of development. |
| 1:05.0 | No, in all seriousness, back in 2004 when I kind of took over the FCPA enforcement program. |
| 1:12.9 | And I think by the time it was handed off to Chuck, it was in its teenage years, tweens. |
| 1:21.4 | Twins? |
| 1:22.4 | Somewhere in there. |
| 1:24.3 | And then I think by the time David inherited the program, it was in its mid-40s. I don't |
| 1:30.4 | mean. |
| 1:30.6 | Majority adult. |
| 1:32.6 | Second part, maybe. Youthful. Youth first come. Seriously, how is it change? I think it has become |
| 1:39.7 | more institutionalized, more sophisticated, a higher priority for the U.S. government writ large, |
| 1:46.9 | and it has become in some ways, and there's no judgment behind this, an industry, a business, |
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