Larry Thompson Appointed Independent Compliance Monitor of VW

Larry Thompson

Volkswagen AG (VW) was sentenced in federal court in Detroit on April 21, 2017, after pleading guilty to three felony counts of: (1) conspiracy to defraud the United States, engage in wire fraud, and violate the Clean Air Act; (2) obstruction of justice; and (3) importation of merchandise by means of false statements. The parties’ plea agreement requires VW to pay a $2.8 billion penalty stemming from the company’s decade-long scheme to sell diesel vehicles containing software designed to cheat on U.S. emissions tests.

The parties also announced that the government had selected NAFUSA member Larry D. Thompson as an independent corporate compliance monitor who will oversee the company during its three-year term of probation.

VW stated,

Mr. Thompson will have a dual role as Independent Compliance Monitor and Independent Compliance Auditor, under the terms of Volkswagen’s plea agreement with the United States Department of Justice (DOJ) and a separate Consent Decree with the DOJ on behalf of the U.S. Environmental Protection Agency, respectively. Mr. Thompson will assess, oversee and monitor the company’s compliance with the terms of its settlements for a period of three years, including measures to further strengthen Volkswagen’s compliance, reporting and monitoring mechanisms and implementation of an enhanced compliance and ethics program. Mr. Thompson will also be tasked with certifying that Volkswagen’s compliance program is able to detect something like the diesel matter and prevent it from happening again.

Thompson joined the law firm of Finch McCranie, LLP in Atlanta, Georgia, as Counsel in July 2015 and is the former U.S. Deputy Attorney General (2001-2003). He served as the United States Attorney for the Northern District of Georgia (1982-1986). He currently serves as the John A. Sibley Professor of Corporate and Business Law at the University of Georgia School of Law. He also served as Executive Vice President of Government Affairs, General Counsel and Corporate Secretary of PepsiCo, Inc. Thompson earned his law degree at the University of Michigan.