About
FCPA enforcement is on the rise… and shows no sign of abating. The Securities and Exchange Commission and the Department of Justice are vigorously policing the activities of U.S. firms to ensure strict compliance with anti-bribery and accounting provisions of the FCPA. They have expanded enforcement and obtained record-high and criminal penalties against companies and individuals for FCPA violations. They also conduct seamless investigations utilizing their joint resources and SEC enforcement actions and DOJ prosecutions are often announced simultaneously. And with the United States and other countries pursuing ways to further discipline companies and individuals making illicit payments in international transactions, there is no escape from these requirements.
Because FCPA enforcement actions tend to be high profile, there can be enormous consequences for the target, including grueling investigations, hefty monetary penalties and negative publicity. U.S. companies must develop effective internal FCPA compliance policy and training programs that facilitate compliance with FCPA requirements and mitigate damage in the event a violation takes place. Civil and criminal penalties are rising, cases are high profile and yesterday's knowledge is simply not enough to make the right decisions today.
ACI's Foreign Corrupt Practices Act publication is a rare opportunity to get an update on enforcement and policy initiatives from
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Government officials and FCPA attorneys and learn how industry is setting up internal controls to comply in this constantly changing global legal landscape. The publication will include the latest information on:
- The impact of recent U.S. and international FCPA cases on your compliance programs
- Benefits and risks of voluntary disclosures – from the SEC and DOJ perspective
- The impact of the expanded use of compliance monitors
- How to meet the compliance challenges of gifts and hospitality
- Strategies to convey the ethics and compliance culture to company employee and officials
- Structuring transactions to mitigate FCPA risk
- Establishing FCPA-compliant internal accounting controls and record-keeping
Contents & Contributors
THE IMPACT OF RECENT FCPA ENFORCEMENT TRENDS ON VOLUNTARY DISCLOSURE
Martin J. Weinstein, Wilkie, Farr & Gallagher
DIGESTS OF CASES AND REVIEW RELEASES RELATING TO BRIBES TO FOREIGN OFFICIALS UNDER THE FOREIGN CORRUPT PRACTICES ACT OF 1977
Danforth Newcomb, Shearman & Sterling LLP
FOREIGN CORRUPT PRACTICES ACT: IMPLICATIONS FOR MERGERS AND ACQUISITIONS
Dale Chakarian Turza, Cadwalader Wichersham & Taft LLP
ENFORCEMENT OF THE OECD ANTI-BRIBERY CONVENTION: LATEST TRENDS
Nicola Bonucci, Organization for Economic Co-operation and Development
ENFORCEMENT OF THE FCPA IN THE UNITED STATES: TRENDS AND THE EFFECTS OF INTERNATIONAL STANDARDS
Lucinda A. Low, Steptoe & Johnson LLP
FCPA COMPLIANCE 2006 UPDATE
William F. Pendergast, Dickinson Landmeier LLP
FCPA COMPLIANCE CHALLENGES: GIFTS AND HOSPITALITY FOR GOVERNMENT OFFICIALS
Margaret M. Ayres, David Polk & Wardwell
GIFTS, HOSPITALITY AND TRAVEL
Alexandra A. Wrage, TRACE International, Inc.
IMPACT OF 2004 AMENDMENTS TO THE FEDERAL SENTENCING GUIDELINES ON CORPORATE ETHICS AND COMPLIANCE PROGRAMS
Jay G. Martin, Baker Hughes Incorporated
HOW MUCH DUE DILIGENCE IS ENOUGH?
Howard O. Weissman, Lockheed Martin Corporation
MEETING THE FCPA'S ACCOUNTING REQUIREMENTS IN TODAY'S REGULATORY ENVIRONMENT
Gregory S. Bruch, Foley & Lardner LLP
CONTROLLING THE MONEY: HOW TO SET UP INTERNAL CONTROLS TO SUPPORT FCPA AND SARBANES-OXLEY COMPLIANCE
Gary Giampetruzzi, Pfizer Inc.
INTERACTING WITH GOVERNMENT OFFICIALS: UNDERSTANDING THE U.S. FOREIGN CORRUPT PRACTICES ACT AND THE FUNDAMENTALS OF A PROGRAM OF COMPLIANCE
Eric F. Grossman, Morgan Stanley & Co. Inc.
Homer E. Moyer, Jr., Miller & Chevalier Chartered
Scott W. Muller, Davis, Polk & Wardwell
US BUSINESS AND CORRUPTION IN CHINA: THE FCPA MINEFIELD
Patrick M. Norton, O'Melveny & Myers LLP
Publication Details