FCPA and Global Anti-Corruption

Nearly one Year after DOJ unveiled its first-ever Department-Wide Corporate Enforcement Policy, companies, compliance leaders, and defense counsel have had an opportunity to assess how the new framework is being implemented in practice. This panel will examine how the policy has influenced corporate decision-making, FCPA and other enforcement outcomes, and compliance strategies during its first year, while exploring what organizations should expect heading into 2027.

• Evaluating DOJ’s first year of CEP implementation: Have the promised benefits of self-disclosure, cooperation, and remediation materialized in practice?
• What companies can learn from the first resolutions, declinations, and “near miss” disclosures under the new framework
• How organizations are reassessing internal investigations, escalation procedures, voluntary disclosure decisions, and remediation strategies to align with DOJ’s expectations
• Whether the “One DOJ” approach has reduced uncertainty and forum-shopping—or simply shifted how companies evaluate enforcement risk
• Looking ahead: anticipated enforcement trends, disclosure strategies, and key areas companies should monitor as DOJ enters the second year of the policy

As DOJ priorities increasingly intersect with cartels, transnational criminal organizations (TCOs), narcotics trafficking, illicit finance, and national security concerns, companies must rethink how they assess and respond to corruption and third-party risk. This session will explore:

• How the current Administration’s focus on cartels, TCOs, narcotics trafficking, and national security is reshaping corruption risk assessments, enforcement priorities, and expectations for corporate compliance programs
• Where traditional anti-bribery and corruption risks intersect with cartel and TCO activity, including bribery, extortion, illicit payments, procurement fraud, customs-related risks, and interactions with government officials
• How companies should adapt risk-assessment methodologies when potential criminal-network exposure becomes an additional dimension of third-party and market risk
• How to distinguish traditional corruption and third-party red flags from indicators of potential cartel or TCO involvement—and determine when heightened investigation or escalation is warranted
• How legal, compliance, security, procurement, finance, and business teams should coordinate when potential cartel/TCO exposure is identified

As U.S. enforcement priorities shift, foreign regulators are increasingly taking center stage. Hear directly from leading enforcement authorities from the UK, France, Switzerland and Norway on emerging enforcement trends, cross-border cooperation, and what multinational companies should expect from non-U.S. anti-corruption authorities moving forward.

Wars, humanitarian crises, reconstruction efforts, shifting trade policies, and unstable governments continue to create significant corruption and compliance risks for multinational organizations. At the same time, evolving enforcement priorities and an increasingly complex regulatory landscape are prompting Chief Compliance Officers to rethink how they demonstrate value and position compliance as a strategic business partner.

This interactive roundtable will explore how leading CCOs are:

• Adapting their anti-corruption programs to address risks arising from conflicts and instability involving current geopolitical flashpoints
• Navigating changing enforcement expectations, heightened third-party risk, emergency procurement, humanitarian operations, and opaque intermediaries
• Strengthening resilience and enabling responsible business growth even amid geopolitical volatility and inconsistent regulatory and enforcement trends

Voluntary self-disclosure remains one of the most consequential decisions a company can make when potential misconduct is identified. Although the U.S. DOJ continues to encourage prompt self-disclosure through its Corporate Enforcement Policy and cooperation incentives, evolving enforcement trends have introduced greater uncertainty into the decision-making process. Organizations must now weigh not only the potential benefits of disclosure, but also the possibility of criminal enforcement despite cooperation, as well as the implications of emerging issues such as national security, before determining the appropriate path forward. In this timely session, our panelists will address considerations surrounding:

• The DOJ’s new Corporate Enforcement Policy and the criteria for obtaining a DPA or NPA
• The grey areas of the “prompt reporting” requirement
• Balancing the potential benefits of cooperation credit against legal, business, reputational, and enforcement risks
• Takeaways from recent declinations and resolutions – including lessons from the Millicom, Balt, Smartmatic and Scoular matters
• Building alignment between compliance, legal, executive leadership, and outside counsel before engaging with the government
• Practical considerations for when, how, and what to disclose once the decision has been made

Companies continue to struggle with investigations and compliance oversight in jurisdictions where transparency is limited and local enforcement is unpredictable. This session will focus on practical strategies for conducting investigations, gathering evidence, navigating data privacy restrictions, and maintaining visibility in challenging and opaque markets. Topics of discussion will include:

• Gathering Evidence Across Borders: Practical strategies for collecting, preserving, and accessing evidence when local laws, data restrictions, and limited transparency create obstacles
• Navigating Data Privacy & Localization Requirements: Balancing investigative needs with data privacy, cybersecurity, and data localization requirements in complex jurisdictions
• Uncovering Beneficial Ownership: Identifying true owners, intermediaries, and hidden relationships when corporate structures and ownership information are difficult to verify
• Managing Local Investigations & Enforcement Risks: Strategies for conducting effective investigations where local enforcement is unpredictable, resources are limited, or government cooperation is challenging
• Strengthening Cross-Border Cooperation: Leveraging local teams, external counsel, forensic resources, and international partners to maintain visibility and drive investigations forward

As DOJ, SEC, and other enforcement agencies continue to expand and promote whistleblower programs, companies face increasing pressure to ensure employees raise concerns internally before turning to government authorities. Join this panel as they share practical strategies for increasing internal reporting, responding effectively to concerns, and reducing the risk that employees bypass company channels in favor of external rewards. Discussion Topics Include:

• How government whistleblower programs are changing employee reporting behavior and corporate compliance strategies
• Building a culture of trust: What encourages employees to report concerns internally rather than externally
• Lessons learned from compliance leaders on investigations, triage, feedback loops, and anti-retaliation practices that strengthen internal reporting systems
• Measuring the effectiveness of speak-up programs and identifying warning signs that employees may be losing confidence in company reporting channels
• Aligning incentives, training, and communications to reinforce the value of internal reporting while responding to growing external whistleblower opportunities

Compliance functions are increasingly converging to create efficiencies across organizations. This panel will explore how companies are integrating anti-corruption, AML and sanctions compliance into unified risk management frameworks. Speakers will discuss governance models, shared controls, data integration, screening efficiencies, and cross-functional collaboration strategies.

• Examine governance models that enable greater coordination, accountability, and efficiency across compliance functions.
• Discuss opportunities to leverage shared controls, integrated data, and technology across multiple risk areas.
• Evaluate screening and monitoring efficiencies achieved through centralized or coordinated compliance processes.
• Share practical strategies for strengthening cross-functional collaboration while maintaining effective risk oversight.

China remains one of the highest-risk—and most consequential—jurisdictions for multinational companies. In the past year alone, regulators have issued major updates to bribery enforcement guidance, intensified enforcement against hidden corruption schemes and intermediaries, launched new healthcare and procurement-focused crackdowns, and announced plans for a dedicated cross-border anti-corruption law. This practical discussion will explore how leading companies are adapting their compliance programs, investigations strategies, and third-party oversight frameworks to address emerging risks while maintaining business operations in China.

Discussion Points:

• China’s new 2026 update to bribery-related judicial guidance, and what it means for corporate bribery risk assessments there
• The growing focus on “hidden corruption,” intermediaries, brokers, and third-party relationships
• Managing distributor, channel partner, and healthcare procurement risks amid China’s continuing healthcare crackdown
• Volume-Based Contracting (VBC), public procurement reforms, and emerging corruption risks
• China’s proposed cross-border anti-corruption law and the implications for multinational companies
• What should compliance teams be doing now to prepare for the next phase of Chinese anti-corruption enforcement?

As anti-corruption enforcement priorities evolve and political narratives shift, how can compliance leaders keep ethics and integrity at the forefront of business decision-making? This interactive discussion will explore:

• Practical strategies for maintaining organizational engagement when enforcement feels less certain
• How companies are leveraging training and culture-building initiatives to reinforce compliance expectations, strengthen employee decision-making, and embed ethics and integrity into day-to-day operations—regardless of the enforcement landscape
• Translating compliance risks into business risks that resonate with directors and executive leadership
• Securing Board support for critical compliance initiatives, technology investments, and additional resources amid budget pressures and regulatory uncertainty

Third-party risk remains the single greatest concern for many compliance teams—but budgets are tightening. This panel will examine how organizations are redesigning TPDD programs to be scalable, risk-based, defensible, and efficient. Topics will include:

• Moving from one-size-fits-all to risk-based due diligence: How organizations are tailoring the depth and frequency of reviews to third-party risk
• Leveraging technology and automation: Practical ways to use AI, data, and workflow automation to reduce manual effort while maintaining quality and oversight
• Building a sustainable operating model: How compliance teams can align people, processes, technology, and budgets to support scalable TPDD programs
• Strengthening ongoing monitoring: Strategies for identifying emerging risks between onboarding and periodic reviews without creating unnecessary workload
• Making programs defensible to regulators and auditors: What good documentation, governance, escalation, and risk-based decision-making look like in practice

Life sciences companies continue to operate in an increasingly complex regulatory environment marked by heightened scrutiny of healthcare fraud and abuse, growing expectations around third-party oversight, and persistent corruption risks across global operations.

This session will explore how leading organizations are adapting their compliance programs to address evolving enforcement expectations while supporting innovation, growth, and patient access worldwide.

Topics include:

• Preparing for evolving enforcement priorities related to healthcare fraud and abuse, and identifying practical steps organizations can take to strengthen compliance programs and investigative readiness.
• Examining corruption and misconduct risks associated with healthcare professional (HCP) interactions, patient support and access programs, grants, sponsorships, and market access activities in higher-risk jurisdictions.
• Managing compliance challenges involving distributors, agents, contract research organizations (CROs), and other third parties across clinical development and commercial operations.
• Aligning anti-corruption controls with healthcare-specific compliance requirements, including obligations under the False Claims Act, Anti-Kickback Statute, and related global regulatory frameworks.