Future of FCPA Compliance Series
Ephemeral Communications, Cooperation Credit and DOJ Expectations: The Newest, High Stakes Risks on the Line – from Employment Litigation, Data Privacy to FCPA Penalty Exposure
Kenneth Blanco
Chief Compliance Officer, Financial Crimes Unit
Citigroup Inc.
David N. Kelley
Partner
Dechert LLP
Rebecca Rohr
Head of Corporate & Government Investigations
Ericsson
Neil T. Smith
Partner
K&L Gates LLP
Patrick F. Stokes
Partner
Gibson, Dunn & Crutcher LLP
During this critically important panel, speakers will unpack some of the biggest issues and worst case scenarios when trying to meet DOJ expectations for cooperation — and the latest best practices for mitigating multiple layers of liability risks:
- The dilemma with employee personal devices being used for bona fide work purposes
- Tensions and issues that can arise when employees refuse to cooperate with corporate policies
- Deciding whether or not to terminate an employee who refuses to cooperate
- Litigation costs and challenges in the context of privacy and message retrieval
- Revisiting your policy amid the interplay of GDPR risks
- Implementing an e-discovery program relating to messaging app
- When you can ask for employees’ personal devices for review
- Retaining counsel for the employee: Determining your obligations as an employer
- What can help to yield cooperation credit—and what has fallen short