Former U.S. Deputy Attorney General Larry D. Thompson and Team Complete Monitorship in Volkswagen AG Emissions Proceedings

The Independent Corporate Compliance Monitor and Auditor for Volkswagen AG, Larry D. Thompson, announced today that Volkswagen AG and its subsidiaries and affiliates met the commitments established under the terms of its 2017 plea agreement with the U.S. Department of Justice (DOJ). (Note that Porsche AG and Porsche Cars NA were excluded entirely from the monitorship.) Since his appointment in 2017, Thompson and his team have worked to assess whether Volkswagen’s compliance and ethics programs were reasonably designed and implemented to prevent and detect violations of anti-fraud and environmental law.

The U.S. government appointed Thompson, a former U.S. Deputy Attorney General and currently counsel at Atlanta-based Finch McCranie, LLP, as the Independent Corporate Compliance Monitor and Auditor for Volkswagen. His appointment was part of Volkswagen’s criminal plea agreement stemming from the company’s scheme to sell diesel vehicles containing software designed to cheat on U.S. emissions tests. Thompson and his team oversaw Volkswagen’s compliance reforms and successful implementation of the terms of the plea agreement.

“In three years, Volkswagen AG has become a different and better company,” said Thompson. “Volkswagen can be proud of the progress it has made. It will require continued vigilance, but the structures and processes in place and the commitments at all levels of the company, along with the oversight of the Supervisory Board, can make Volkswagen a long-term and sustainable ethics, integrity, and compliance success.”

During his tenure as Deputy Attorney General from 2001 to 2003, Thompson led the DOJ’s National Security Coordination Council, as well as the government-wide Corporate Fraud Task Force. Previously, Thompson was a partner with Atlanta-based King & Spalding, LLP. Earlier in his career, he served as U.S. Attorney for the Northern District of Georgia, and as Independent Counsel for the Department of Housing and Urban Development Investigation. Thompson also served as Executive Vice President for Government Affairs and General Counsel for PepsiCo.

To assist him in monitoring Volkswagen’s corporate compliance, Thompson assembled a team of leading corporate fraud, environmental, and compliance experts. Leaders of the team included:

Thompson was also assisted by an accomplished group of subject matter experts from pertinent areas including emissions, compliance, ethics and integrity, fraud, risk management, legal and audit. “I am honored to have led such a knowledgeable, experienced and absolutely dedicated team,” said Thompson. “I cannot say enough about their hard work, diligence, efficiency, and professionalism. Obviously, this project was critically important on numerous levels, but this was the right team for the challenge. All team members should be proud of their outstanding collective accomplishment.”