THE WEEKLY BRIEF

Thursday, April 2, 2026

Welcome to your look at what CCI is covering this week:

Does Your FCPA Compliance Program Even Work in the Persian Gulf?

With US military action reshaping the Middle East, the Persian Gulf region could soon start to look more like opportunity than risk. Keep that in your mind as you read this piece.

In four cases examined here, Western multinationals paid a combined $5 billion to resolve FCPA violations connected to GCC markets — and in every case, the compliance program was operational, the due diligence files were complete and the audit committees received clean reports. The controls worked exactly as designed. That's the problem.

Majid Mumtaz, an internal audit and governance leader in the GCC, identifies the features of Persian Gulf commercial architecture that make a standard Western compliance framework structurally blind, or, as he says, like using a thermometer to measure wind speed.

MORE ON THE FCPA

What Detractors Keep Getting Wrong About the FCPA

Last year's FCPA pause revived a familiar complaint: that US anti-bribery enforcement handicaps American companies overseas. Counterpoint: It rewards companies that compete on quality rather than payoffs. By Martin J. Weinstein, Cadwalader, Wickersham & Taft

LEGAL, RISK & REGULATION

• US Targeting TCO's Role in 'Scam Centers,' by John Carlin, Roberto Gonzalez, Ian Richardson & Sam Kleiner, Paul, Weiss

• Smaller Investment Advisers Staring Down June Deadline on Reg S-P by Paul Foley, Cole Beaubouef, Kiki Scarff & John Faust, Baker Donelson

IN THE LOOP: AI & COMPLIANCE

• Is the Three Lines Model Still Valid in the Agentic Era? by Antonella Serine KLA Digital, KLA Digital

COMPLIANCE PROGRAM BEST PRACTICES

• When Efficiency Becomes Fragility in Unstable Environments by Stuart J. Green, author & leadership adviser

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