Insights From Albemarle and JBS Compliance Insiders About Upscaling Compliance After a Settlement

When a company settles an FCPA issue with the DOJ and SEC, one of the top priorities – both for the company and the government – is to make compliance improvements to help prevent future issues. But the remediation road can be tricky and is different for every company. The cooperation and remediation efforts that led to a three-year non-prosecution agreement for Albemarle Corporation (Albemarle) and to completion of a three-year cooperation plea agreement for Brazilian-based J&F Investimentos S.A. (J&F) and its subsidiary JBS S.A. (collectively JBS), were the subject of two engaging fireside chats at Compliance Week’s 19th annual national conference in Washington, D.C. This article distills some of the insights and lessons learned from guest speakers Andrew McBride, Albemarle’s former chief risk & compliance officer, and Michael Koenig, JBS’s global chief ethics & compliance officer. For more insights from the conference, see “Embedding Compliance Across the ESG Value Chain” (May 8, 2024); and “In-House Perspectives on Compliance’s Role in Managing New and Emerging Risks” (May 22, 2024).

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