Welcome back to the podcast, bribes, windle, or steel.

I'm Alexandra Rogge.

And today we're looking back at an FCPA case from 2009, Control Components Inc, or CCI.

My guest is Trace colleague, Ilya Antonenko.

Ilya is the director of compliance resources at Trace.

That is, he runs Trace's fantastic research arm.

He's also our GDPR guru and serves as our data protection officer.

Yilia, thank you for joining me.

You're welcome.

Your office is usually about 50 feet from mine, but we haven't seen each other in months,

which is a little strange

now to be speaking over Skype, but I am delighted you agreed to talk about this case.

I should have started by noting that you were the Associate General Counsel at Control Components,

but you arrived there after this matter was resolved, and everything we're going to discuss

is, of course, a matter of public record.

Okay, so why don't you start by describing the facts of the CCI matter?

How did they get into trouble?

I came later on after CCI pled guilty.

I joined in 2010, so I was not part of the problem, but came to fix the problem.

CCI pled guilty to three counts of conspiracy to violate the FCPA and the Travel Act and counts

of violating the FCPA itself.

The misconduct in this case happened over a long period of time since 1998 through 2007, but the DOJ focused just on a number of years

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