DOJ’s Kahn Discusses Layers of “Swiss Cheese” Compliance With AB InBev and UPS Experts

Good compliance officers ask similar questions about their programs, but there are “different good answers for each company and each compliance program,” Dan Kahn, Chief of the DOJ’s Fraud Unit, observed at a recent webinar hosted by AB InBev. Joined by Matt Galvin, global vice president for ethics and compliance at AB InBev, and Mohammed Azam, chief audit and compliance executive at UPS, Kahn discussed how companies can layer compliance to cover holes and what the DOJ is looking for when it evaluates compliance programs, including how pandemic-related budget cuts may affect that evaluation. See “Second Edition of the DOJ/SEC FCPA Resource Guide Spotlights U.S. Enforcers’ Controversial Legal Interpretations” (Jul. 8, 2020).

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