In “Joanne Taylor on the UK Airbus Enforcement Action” (17 Feb. 2020), Tom Fox interviews Joanne Taylor, managing director at K2 Intelligence, about the Airbus deferred prosecution agreement (DPA). Key analysis that Joanne shared include: 

  • Even if an organization gets off to a slow start, is critical to fully cooperate with enforcement authorities in order to get the best outcome. The international cooperation model means that companies that experience similar issues need to ensure that their internal investigation is fully comprehensive in terms of scope and geographical footprint, in order to gain credit in a DPA arrangement.  
  • Companies need to have a robust anti-bribery and corruption risk assessment process in place for identifying key bribery risks within the business and assessing potential controls weaknesses and areas for further deep dive or remediation. It is a fundamental component of any successful bribery corruption program that companies like K2 Intelligence work with clients to implement.
  • Some of the controls that looked fine on paper did not work in practice. There is huge value in independent testing of controls operated by both the business and compliance functions in order to detect where controls are defective.

Listen to the full episode.