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

I'm Alexandra Rogge, and we have a great podcast for you today.

My guests are Drago Koss, chair of the OECD's working group on bribery, amongst many other

responsibilities, and Dan Kahn, former head of the DOJ Fraud

Section's FCPA unit, and is now a partner in Davis-Pokes' DC office representing clients in

criminal and regulatory investigations and in civil and criminal trials. We've discussed the revised

OECD Working Group on Bribery Recommendation on the podcast recently, but we really wanted to

focus today on the very practical implications for companies. So turning this over, Dan,

Drago, thank you for joining me. It's a pleasure to be here. Thanks so much for having us.

The pleasure for me, too. Let's start with just some high-level remarks on the recommendation, and then we'll go

point by point. Is it a resounding success? Is it good as far as it goes, but there's more work to be

done? Dan, I'll start with you, because drag goes a little closer to the issue. Thanks so much.

And I guess what I would say is a couple things to keep in mind. One is that these are just recommendations. And so it's not as though they're going to have an immediate impact. It will take time for the member states to actually put these into practice. And obviously one of the things that the OECD working group on bribery is going to be following is whether, in fact,

the member states do in fact put these into practice. And so I think one is this is going to be

a little bit of a wait and see game. But on the other hand, and the second point is I do think

that these recommendations give a fairly helpful insight into where enforcement authorities' priorities are

right now. And so the fact that there is, for example, that a recommendation on non-trial resolutions,

that's not out of the blue, you've seen a trend with other countries starting to pursue those

types of resolutions in their countries.

Whistleblowers is something that, you know, has been a trend in a number of countries and a number

of regions. And so there are a number of recommendations here that may not actually come into

practice in the foreseeable future. It may take a couple of years, but at the same time, I think it's

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