About
FCPA enforcement is becoming more aggressive in all stages, from investigation
to prosecution. Companies must be vigilant about preventing, detecting and
investigating potential FCPA violations before they damage corporate reputations,
affect the bottom line and shareholder value, and result in increasingly harsher
penalties.
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 targeted companies, 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.
The publication for the ACI's National Forum
on Foreign Corrupt Practices Act is filled with comprehensive, insightful, and practical material on critical FCPA compliance
issues. Benefit from the practical perspective of seasoned
corporate FCPA compliance executives from companies such as Exxon Mobil, Northrop Grumman, Thales,
Lockheed Martin, Motorola, The Boeing Company and Trace International. Get an
update on enforcement and policy initiatives from top
Government officials and FCPA attorneys and learn how industry is setting up internal controls to
comply in this constantly changing global legal landscape. This year's
agenda will include the latest information on:
- The impact of recent FCPA cases on your compliance programs
- Strategies to convey the ethics and compliance culture to company employees
and officials overseas
- When, how, and by whom internal investigations should be conducted
- Implementing anti-corruption compliance programs
- How to work with joint-ventures partners that don't share your
anti-corruption commitment
- Structuring transactions to mitigate FCPA risk
- M&A due diligence
About
FCPA enforcement is becoming more aggressive in all stages, from investigation
to prosecution. Companies must be vigilant about preventing, detecting and
investigating potential FCPA violations before they damage corporate reputations,
affect the bottom line and shareholder value, and result in increasingly harsher
penalties.
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 targeted companies, 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.
The publication for the ACI's National Forum
on Foreign Corrupt Practices Act is filled with comprehensive, insightful, and practical material on critical FCPA compliance
issues. Benefit from the practical perspective of seasoned
corporate FCPA compliance executives from companies such as Exxon Mobil, Northrop Grumman, Thales,
Lockheed Martin, Motorola, The Boeing Company and Trace International. Get an
update on enforcement and policy initiatives from top
Government officials and FCPA attorneys and learn how industry is setting up internal controls to
comply in this constantly changing global legal landscape. This year's
agenda will include the latest information on:
- The impact of recent FCPA cases on your compliance programs
- Strategies to convey the ethics and compliance culture to company employees
and officials overseas
- When, how, and by whom internal investigations should be conducted
- Implementing anti-corruption compliance programs
- How to work with joint-ventures partners that don't share your
anti-corruption commitment
- Structuring transactions to mitigate FCPA risk
- M&A due diligence
Contents & Contributors
FAST PACE OF FCPA ENFORCEMENT CONTINUES
Roger M. Witten, Wilmer Cutler Pickering Hale and Dorr LLP (New York, NY)
CURRENT TRENDS IN INTERNATIONAL ANTI-CORRUPTION ENFORCEMENT
Alan P. Larson, Transparency International-USA (Washington, DC)
INTERNAL INVESTIGATIONS: CONTROLLING COSTS AND DIRECTING THE INVESTIGATION
Homer E. Moyer, Jr., Miller & Chevalier Chartered (Washington, DC)
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 (New York, NY)
IMPLEMENTING ANTI-CORRUPTION COMPLIANCE PROGRAMS: AN EUROPEAN EXAMPLE
Dominique Lamoureux, Thales Group (Paris, France)
BOEING'S APPROACH TO COMPLIANCE OVERSIGHT
Marcie Lombardi, The Boeing Company (Seattle, WA)
COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES ACT
Howard O. Weissman, Lockheed Martin Corporation (Bethesda, MD)
CORPORATE CONSIDERATIONS IN THE PROSECUTION OF INDIVIDUALS
Martin J. Weinstein, Willkie, Farr & Gallagher LLP (Washington, DC)
IDENTIFYING AND ADDRESSING FCPA ISSUES IN CORPORATE TRANSACTIONS
Gary DiBianco, Skadden Arps, Slate, Meagher & Flom LLP (Washington, DC)
M&A DUE DILIGENCE
C. David Morris, Northrop Grumman Corporation (Linthicum, MD)
SUMMARY: INTERNAL CONTROLS AND THE FCPA
Paul V. Gerlach, Sidley, Austin, Brown & Wood (Washington, DC)
ENSURING COMPLIANCE OF CO-VENTURERS
Anne P. McAdams, Exxon Mobil Corporation (Houston, TX)
CONDUCTING DUE DILIGENCE OF COMMERCIAL INTERMEDIARIES TO MINIMIZE RISK OF THIRD PARTY LIABILITY
Alexandra A. Wrage, Trace International (Annapolis, MD)