SUB-SAHARAN AFRICA & MIDDLE EAST ROUNDTABLE
Inside Real World Considerations for Third Party Management and “Localizing” Your Compliance Program

Jan 29, 2019 1:30pm - 5:00pm

Speakers

Bill Gordon
Associate General Counsel
Hercules Offshore, Inc. (Washington, DC)

Ana Pinelas Pinto
Partner
Miranda & Associados (Portugal)

Day 1 - Wednesday, January 30, 2019

7:45
Registration and Continental Breakfast
8:30
Conference Co-Chairs’ Opening Remarks
8:45

THIRD PARTY DUE DILIGENCE and AUDIT SCENARIOS

The Reality of Third Party Management in New, Emerging Markets: Industry Experts Discuss the Unwritten Lessons on How to Get It Right
9:45
How Cross-Border Investigations are Now Unfolding in Practice: Practical Guidance for Multinationals and their Advisors Post-U.S. v. Hoskins
10:30
Coffee & Networking Break
10:45

REAL-LIFE CONSORTIA AND M&A SCENARIOS

“Reading the Tea Leaves” — How to Predict Corruption Risks with Consortia and M&A: Aligning Compliance Objectives with Business Goals when Private Equity is Involved
11:45

MEXICO: PARTNERING WITH PEMEX POST-ENERGY REFORM

Case Study on New Corruption Risks for JVs with a State-Owned Company: Two Pioneer Multinationals Share their Experiences
12:30
Networking Lunch
1:45

ETHICS FOCUS

The Latest and Greatest in Employee Training: Incentivizing Ethical Behavior, Responsibility and Corporate Citizenship to Do the Right Thing
2:30

REAL-LIFE STORIES FROM A CHIEF COMPLIANCE OFFICER

How to Lead Your Organization Through a Multi-Jurisdictional Investigation and Strengthen Your Program
3:15
Coffee & Networking Break
3:30

GOVERNMENT INTERVIEW

FCPA Enforcement and Multi-Jurisdictional Coordination: Key Updates on Evolving Policies, Priorities and Expectations
4:30
Open Q&A Session
5:15
Conference Adjourns

Day 2 - Thursday, January 31, 2019

8:00
Continental Breakfast
8:30
Conference Co-Chairs’ Remarks
8:35

SPECIAL INTERVIEW

In-House Executives Discuss What is Keeping Them Up at Night
9:30

COMPLIANCE ON A BUDGET: MAKING THE TOUGH CALLS

Securing Board Buy-In for a Meaningful Compliance Investment: How to Resonate, Allocate New Resources and Measure ROI
10:30
Coffee & Networking Break
10:45

LIVE DEMO: METRICS AND DATA ANALYTICS

How to Leverage Innovative Solutions to Detect Compliance Successes and Weak Spots
11:15

ECONOMIC SANCTIONS and FCPA DUE DILIGENCE

The Increased Convergence of FCPA and OFAC Due Diligence Requirements: How CCOs are Recalibrating their Anti-Bribery Strategy
12:00

LATIN AMERICA COMPLIANCE UPGRADES

Perspectives on the Lengths and Limits of a Regional vs. Country-Specific Anti-Corruption Compliance Approach
1:00
Networking Lunch
2:15

THE HIDDEN RISKS IN YOUR CONTRACTS: REVIEW OF SAMPLE TERMS AND CONDITIONS

Operationalizing Contracts Terms and Minimizing Indemnities Risks
3:00

MONITORSHIPS IN PRACTICE

More Insights into the Monitorship Process Behind the Curtain
3:45
Networking Break
4:00

GDPR PITFALLS TO AVOID

Taking Stock of GDPR Compliance: Addressing the Expected and Unexpected Impact on Investigations and Third Party Management
4:45

ENCOURAGING INTERNAL WHISTLEBLOWING

The Changing Face of Reporting: How Companies are Evolving their Policies and Procedures to Foster More Cross-Departmental Synergy
5:30
Conference Concludes

Day 1 - Wednesday, January 30, 2019

7:45
Registration and Continental Breakfast
8:30
Conference Co-Chairs’ Opening Remarks

Kelly Thorman
Chief Compliance Officer
Parker Drilling Company (Houston, TX)

Veena Lakkundi
Vice President and Chief Ethics and Compliance Officer
3M (Minneapolis, MN)

8:45

THIRD PARTY DUE DILIGENCE and AUDIT SCENARIOS

The Reality of Third Party Management in New, Emerging Markets: Industry Experts Discuss the Unwritten Lessons on How to Get It Right

Adam J. Falkowitz
Deputy General Counsel
Olympus Corporation of the Americas (Philadelphia, PA)

Marsha M. McIntyre
Director of Compliance
Oxbow Carbon LLC (West Palm Beach, FL)

Larra Call Waldmann
Former Associate General Counsel
Cardinal Health (Miami, FL)

This practical session will feature various complex third party risk management scenarios that will illustrate how to tailor your due diligence to local circumstances, and foster cooperation and compliance from business partners.

  • Who qualifies as a “government official” in countries where large numbers of people are identified as members of a royal family or affiliated with a ruling tribe
  • What are the best ways to manage and use agents in countries that legally require them
  • How to avoid “getting stuck” with a single or limited number of agents when entering a new market
  • How often should you exercise third-party audit rights and how extensive do these audits need to be to satisfy regulators?
  • In negotiations, what to do when the vendor or agent demands a success fee?
  • Choosing the right auditing tool to eliminate third party risks: Pros and cons of building an in-house program vs. outsourcing the audit function
  • When to revisit and possibly terminate the relationship: Concrete examples of tough decision-making

9:45
How Cross-Border Investigations are Now Unfolding in Practice: Practical Guidance for Multinationals and their Advisors Post-U.S. v. Hoskins

Darryl Wegner
Assistant Special Agent in Charge
Federal Bureau of Investigation

William B. Jacobson
Partner
Orrick, Herrington & Sutcliffe LLP (Washington, DC)

Barry Vitou
Shareholder
Greenberg Traurig, LLP (United Kingdom)

  • Lessons learned from the rise in multi-jurisdictional prosecutions and international coordination
  • Revisiting your disclosure calculus in response to recent developments and US DOJ policy implementation
  • U.S. v. Hoskins: The scope of FCPA application
  • Mitigating the risk of “double jeopardy”: When a company can receive a “coordinated” fine or settlement rather than fines by multiple enforcement bodies
  • How to respond to conflicting demands by different enforcement agencies
  • The most essential, must-have skills and tools to manage an investigation across countries and enforcement agencies
  • Cooperation conundrums: Compelled testimony and admissibility across borders, transfer of confidential information, cross-border misalignment of privileges (privilege of location), etc.
  • Best practices for selecting and managing outside counsel
  • Hypothetical case example: A practical illustration of how a case is likely to be handled in the US vs. France vs. Brazil vs. UK vs. China

10:30
Coffee & Networking Break
10:45

REAL-LIFE CONSORTIA AND M&A SCENARIOS

“Reading the Tea Leaves” — How to Predict Corruption Risks with Consortia and M&A: Aligning Compliance Objectives with Business Goals when Private Equity is Involved

Holly Clarke
Partner
Rose Walker LLP (Dallas, TX)

S. Todd Crider
Partner
Simpson Thacher LLP (New York, NY)

Carlos Mena Labarthe
Partner
Creel, García-Cuéllar, Aiza y Enriquez (Mexico)

  • What to do when faced with an acquisition that is not your traditional business
  • How economic pressures are resulting in ever more multiple-player consortia and/or growth by acquisition
  • Assessing risks posed by the purchase or sale of an asset and/or a company affected by an anti-corruption compliance breach, under investigation or in a leniency agreement
  • Assessing DOJ’s offer of a declination with disgorgement to companies who self-report foreign bribery in the context of an M&A
  • When PE is involved and associated risks (e.g., pressure to “deliver numbers”)
  • How a “tainted” company can make itself attractive as a consortia partner or acquisition target even if it is under ongoing compliance monitorship
  • Deciding between M&A, JV and consortium depending on industry type and business needs
  • Statute of limitations on successor liability: When to put a consortia or M&A deal on hold

11:45

MEXICO: PARTNERING WITH PEMEX POST-ENERGY REFORM

Case Study on New Corruption Risks for JVs with a State-Owned Company: Two Pioneer Multinationals Share their Experiences

Carlos Benjamin Silva Hernandez
Deputy Legal Compliance Officer
PEMEX (Mexico)

Jenny Craymer
Manager, Compliance
BHP Billiton (Houston, TX)

BHP Billiton is the first international company to launch a partnership with state-owned PEMEX in a joint venture after Mexico’s recent landmark energy sector reform, a law that now allows non-Mexican companies to bid for oil & gas production contracts. The panelists will discuss their partnership, pledge by Mexico’s new President for a restructuring of PEMEX and the broader energy landscape.

  • Will Mexico’s new government respect or undo recent changes to the energy reform?
  • How existing contracts (in JV agreements) between PEMEX and its international partners might be impacted by changes to the energy reform
  • Mexico’s strict anti-corruption safeguards, such as for gifts, travel, entertainment & hospitality

12:30
Networking Lunch
1:45

ETHICS FOCUS

The Latest and Greatest in Employee Training: Incentivizing Ethical Behavior, Responsibility and Corporate Citizenship to Do the Right Thing

James Scroggins
Chief Compliance Officer
MHI Shared Services America, Inc. (Houston, TX)

Bill Gordon
Associate General Counsel
Hercules Offshore, Inc. (Washington, DC)

This special session will focus on the ethical responsibilities of multinationals in the context of recent developments in the United States. Speakers will practically discuss compliance beyond anti-corruption, the importance of good governance and corporate reputation.

  • Fine-tuning training: Ensuring employees in departments with greater exposure to corruption risks receive enhanced training (e.g., commercial/sales team vs. marketing division)
  • Finding the right nuances in messaging to US vs. international employees at all levels
  • Measuring the effectiveness of your training program and subjecting it to regular review
  • How to instill the right culture across departments via an integrity skills competency program
  • Embedding ethical decision-making skills into department heads’ day-to-day conduct
  • Implementing separate training programs for in-house employees and third parties: What are the associated risks of failing to do so?

2:30

REAL-LIFE STORIES FROM A CHIEF COMPLIANCE OFFICER

How to Lead Your Organization Through a Multi-Jurisdictional Investigation and Strengthen Your Program

Michael F. Munro
Director of Global Outreach and Board Advisor
Odebrecht, Engenharia & Construção (Houston, TX)
(Former Chief Compliance Officer, Odebrecht, Engenharia & Construção)

During this special panel, conference delegates will be taken on a first-hand tour of the experiences of two Chief Compliance Officers, who guided their companies through multijurisdictional investigations and negotiated multicountry settlements. Delegates will benefit from unique insights into the thought-process of the panelists, including:

  • How to lead your company through the investigation, as well as settlement negotiations
  • Assessing probation periods
  • How to create (from scratch) or adjust a compliance program to meet multi-jurisdictional anti-corruption requirements
  • How to anticipate potential future compliance issues that may arise post-settlement
  • Preparing for a successful monitorship from start to finish

3:15
Coffee & Networking Break
3:30

GOVERNMENT INTERVIEW

FCPA Enforcement and Multi-Jurisdictional Coordination: Key Updates on Evolving Policies, Priorities and Expectations

Daniel Kahn
Chief, FCPA Unit, Fraud Section, Criminal Division
U.S. Department of Justice

Ryan K. Patrick
U.S. Attorney for the Southern District of Texas
U.S. Department of Justice

Perrye K. Turner
Special Agent in Charge – Houston Field Office
Federal Bureau of Investigation, FBI (Houston, TX)

David Reece
Assistant Director, FCPA Unit
Division of Enforcement, United States Securities and Exchange Commission

Moderator

Matthew J. Jacobs
Partner
Vinson & Elkins LLP (San Francisco, CA)

This exclusive interview will allow for an in-depth discussion of current USDOJ, SEC and FBI enforcement priorities.

4:30
Open Q&A Session

Daniel Kahn
Chief, FCPA Unit, Fraud Section, Criminal Division
U.S. Department of Justice

Ryan K. Patrick
U.S. Attorney for the Southern District of Texas
U.S. Department of Justice

Perrye K. Turner
Special Agent in Charge – Houston Field Office
Federal Bureau of Investigation, FBI (Houston, TX)

David Reece
Assistant Director, FCPA Unit
Division of Enforcement, United States Securities and Exchange Commission

Moderator

Jay Martin
Associate General Counsel and Chief Compliance Officer
Baker Hughes, a GE Company (Houston, TX)

This panel constitutes a special opportunity for the audience to engage in live Q&A with US government representatives.

5:15
Conference Adjourns

Day 2 - Thursday, January 31, 2019

8:00
Continental Breakfast
8:30
Conference Co-Chairs’ Remarks
8:35

SPECIAL INTERVIEW

In-House Executives Discuss What is Keeping Them Up at Night

Francisco Petros
Member, Governing Board at BRF S.A.
Former Board Member and President of Succession and Compensation

Committee at Petróleo Brasileiro S.A. – Petrobras

Michael Sumruld
Senior Vice President & Chief Financial Officer
Parker Drilling Company (Houston, TX)

Sue Kean
Vice President, General Counsel & Corporate Secretary
Rubicon Oilfield International

Moderator

Andrew M. Levine
Partner
Debevoise & Plimpton LLP (New York, NY)

This much-anticipated exchange has been conceived to illustrate the true big picture perspectives of major stakeholders on key risk factors. Amid an evolving enforcement landscape, the conversation will cover, among other things:

  • Determining the nature of relationship between the board, CEO, GC and CCO/compliance department
  • The meaning of the Corporate Enforcement Policy’s criterium of “authority and independence of the compliance function and the availability of compliance expertise to the board”
  • How board members perceive their responsibility and decision-making power, including their fiduciary role in ensuring the right policies and systems
  • What audit committee members of the board are most interested in hearing
  • Dovetailing business and compliance objectives
  • Board-led investigations: The board members’ role as supervisor of an internal investigation, including the relationship with outside counsel

9:30

COMPLIANCE ON A BUDGET: MAKING THE TOUGH CALLS

Securing Board Buy-In for a Meaningful Compliance Investment: How to Resonate, Allocate New Resources and Measure ROI

Julia Symon
Vice President and Chief Compliance Officer
KBR, Inc. (Washington, DC)

Tony Fiore
Director and Associate General Counsel
Denham Capital (Houston, TX)

Moderator

Jeffrey S. Johnston
Partner
Vinson & Elkins LLP (Houston, TX)

  • Best practices for CCOs to turn their department into a strategic and valued, integrated and indispensable part of the company
  • Demonstrating your value to the c-suite and company board: How to quantify the value of the in-house compliance function and shift the “cost-center” mentality
  • How to clearly delineate “must-haves” and “nice-to-haves” for your compliance program (outsourcing third party and vendor screening vs. bringing it in-house, frequency of performing audits, etc.)
  • Getting the most bang for your buck: Optimizing and effectively allocating resources

10:30
Coffee & Networking Break
10:45

LIVE DEMO: METRICS AND DATA ANALYTICS

How to Leverage Innovative Solutions to Detect Compliance Successes and Weak Spots

Sergio V. Leal
Compliance Officer
Bilfinger North America Inc.

  • Compliance monitoring: Why is it important to measure compliance?
    • Understanding what you can measure and monitor
    • Compliance monitoring in retail
  • You have compliance metrics, now what?
    • Making sure that the data is consistent and you can trust it
    • When you need to stop monitoring and start fixing
    • Evaluating trends, predictive analytics
  • Compliance monitoring and risk assessment
    • Conducting an effective risk assessment starts with data monitoring
    • Allocation of resources to risk
  • How to monitor your anti-corruption program:
    • TPIs: number of TPIs, due diligence cycle, approval and rejection rates, contract execution, audit rights, training, re-certification
    • Business expenses and entertainment: amount, pre-approvals, supporting documentation
    • Donations: what is being donated, approval of donation recipients, reasons for the donation, supporting documentation
    • Financial Controls: 3 lines of defense

11:15

ECONOMIC SANCTIONS and FCPA DUE DILIGENCE

The Increased Convergence of FCPA and OFAC Due Diligence Requirements: How CCOs are Recalibrating their Anti-Bribery Strategy

Daniel Hudson
Assistant General Counsel
Tidewater Marine (Houston, TX)

Margaret Mousoudakis
Assistant Compliance Officer
LyondellBasell (Houston, TX)

Kelly Thorman
Chief Compliance Officer
Parker Drilling Company (Houston, TX)

Michael X. Marinelli
Shareholder
Greenberg Traurig (Austin, TX)

  • The newest risks under various sanctions regimes and the Global Magnitsky Act
  • The legal environment post-Executive Order 13818 (December 2017): How the U.S. is now imposing punitive measures resulting from acts of corruption and public bribery
  • In what instances does the Magnitsky Act enhance multinationals’ exposure to corruption and beneficial ownership risks?
  • How much vetting is now reasonable/enough? Does the type and depth of due diligence differ between private and state-owned enterprises?
  • The risks of overlapping OFAC, DOJ, SEC and foreign enforcement actions for sanctions violations and bribery

12:00

LATIN AMERICA COMPLIANCE UPGRADES

Perspectives on the Lengths and Limits of a Regional vs. Country-Specific Anti-Corruption Compliance Approach

Sonia Zeledon
Regional Counsel – Americas ECI
Nokia (Miami, FL)

Marta Johnson
Vice President & Chief Compliance Officer
American Bureau of Shipping, ABS

Brandt Leibe
Partner
King & Spalding LLP (Houston, TX)

Guy Singer
Partner
Orrick, Herrington & Sutcliffe LLP (New York, NY)

  • Recent successes in compliance upgrades in response to the new enforcement landscape
  • Regional anti-corruption laws exists, but are they being enforced?
  • Argentina’s “Notebook Case:” The next Lava Jato?
  • Leniency settlements for individuals and companies in exchange for cooperation: To whom you should disclose a local anticorruption breach (local vs. US authorities)

1:00
Networking Lunch
2:15

THE HIDDEN RISKS IN YOUR CONTRACTS: REVIEW OF SAMPLE TERMS AND CONDITIONS

Operationalizing Contracts Terms and Minimizing Indemnities Risks

Brent Benoit
Chief Compliance Officer
National Oilwell Varco (Houston, TX)

Doug Cohan
Deputy Compliance Officer, Senior Assistant General Counsel
Hess Corporation (Houston, TX)

Philip Islip
Vice President Legal and Contracts – North America, Central America, and Asia Pacific
SBM Offshore (Houston, TX)

Josh Wallenstein
Managing Member
The Wallenstein Law Group (Houston, TX)

This practical panel will explore the operational challenges and solutions for drafting, negotiating and administering compliance terms and conditions. It will also address the importance of measuring the degree of corruption risks embedded in contractual language, specifically with regard to indemnities. Topics covered will include:

  • Understanding how much risk you are truly mitigating in your contracts
  • The lengths and limits of ABAC-specific clauses
  • Rethinking the ever-increasing number of AC indemnity provisions and stemming additional piling on
  • Effectively communicating with business partners, contractors and third parties on various contractual language addressing corruption risks: Audit rights, representations, mutual commitments, etc.

3:00

MONITORSHIPS IN PRACTICE

More Insights into the Monitorship Process Behind the Curtain

Laurie Waddy
Head Group Compliance Officer
Bilfinger SE (Germany)

Grant W. Nichols
Partner
King & Spalding LLP (Austin, TX)

S. Joy Dowdle
Partner
Paul Hastings LLP (Houston, TX)

During this interview, delegates will have the chance to hear about a first-hand experience with a company’s monitorship. Concretely, the panel will address, among other issues:

  • Getting used to a monitor’s visits: How to prepare the company and various in-house departments for questions (HR, AR, procurement/supply chain, business teams, etc.)
  • Each monitor typically has a different compliance philosophy and priorities: How to “satisfy” your monitor
  • Being proactive: How to anticipate what the monitor might ask
  • Monitorships are expensive: How to manage the cost

3:45
Networking Break
4:00

GDPR PITFALLS TO AVOID

Taking Stock of GDPR Compliance: Addressing the Expected and Unexpected Impact on Investigations and Third Party Management

Allen W. Chiu
Chief Compliance Officer & Global Head of Litigation
Genesys (Daly City, CA)

Una A. Dean
Partner
Fried, Frank, Harris, Shriver & Jacobson LLP (New York, NY)

Alexander Blumrosen
Partner
KAB - KUCKENBURG BURETH BOINEAU et Associés (France)

This panel will explore two of the most often-raised challenges when it comes to the GDPR and data privacy.

  • Obtaining data and information to vet third parties
  • The delicate balance been GDPR, cooperation and data access for internal investigations

4:45

ENCOURAGING INTERNAL WHISTLEBLOWING

The Changing Face of Reporting: How Companies are Evolving their Policies and Procedures to Foster More Cross-Departmental Synergy

Ameer Gopalani
Global Ethics & Compliance Director
American Bureau of Shipping, ABS (Houston, TX)

Veena Lakkundi
Vice President and Chief Ethics and Compliance Officer
3M (Minneapolis, MN)

Joseph Burke
Chief Ethics & Compliance Officer and Employment Counsel
Quest Software Inc. (Austin, TX)

  • Best practices for handling reporting issues (or launch an internal investigation) in the #MeToo era
  • Managing the increasing overlap of compliance, ESG/CSR matters and adherence to the UN Global Compact
  • Putting in place controls to effectively guard against any form of retaliation
  • Ensuring the compliance department becomes involved with handling an internal complaint from the start
  • Beyond FCPA compliance: Optimizing your global compliance program via free flow data and information across departments (compliance, legal, HR, payroll, sales, etc.)
  • Getting to “yes, but”: Best practices to communicate with the business team about whistleblowing, internal reporting and anti-retaliaton

5:30
Conference Concludes

ANTI-CORRUPTION CASE REVIEW
A Complete Refresher on the Most Important Lessons Learned from Key US and International Investigations and Settlements: Key Takeaways to Optimize Your Global Compliance Program

Jan 29, 2019 9:00am - 12:30pm

$600

Speakers

Michael Pacella
Vice President, Global Anti-Corruption and Investigations Counsel
Zimmer Biomet

Jaime B. Guerrero
Partner
Foley & Lardner LLP

What is it about?

(Registration begins at 8:30 am)

Led by senior in-house experts in the anti-corruption compliance and investigations fields, this highly practical working group offers a unique opportunity for you and your team to ensure that you are full up-to-speed on the most significant corruption-related cases, and how to leverage the lessons learned to enhance your program moving forward. Take advantage of this unique, smaller-group setting to have your specific questions answered and benchmark with peers. Topics will include:

  • Recent cases impacting the future of FCPA settlements, including Kokesh v. SEC
  • US v. Hoskins — Will the reach of US enforcers to pursue foreign individuals be affected, perhaps even curbed?
  • The “anatomy” of a bribe: What has triggered suspicion and a government investigation
  • A deep dive into key investigations and settlements, and what they reveal about DOJ and SEC expectations
  • Which cases have led to an SEC settlement, but a DOJ declination
  • Trends in settlements, including penalty structures and remediation requirements
  • Industries that are increasingly under the microscope in recent memory
  • How the agencies have interpreted “cooperation”
  • A review of the first examples of the DOJ’s avoidance of “piling on” (Ensco, ING) and the impact on your anti-corruption compliance strategy
  • Which circumstances have led to declinations, DPAs and NPAs
  • Insights on DOJ and SEC coordination with foreign enforcement agencies
  • Lessons learned for mitigating enforcement risks and interfacing with the agencies
  • How to leverage the key lessons from settlements toward effecting compliance improvements in your organization
  • A close look at current investigations and emerging enforcement trends
  • As enforcement becomes more global and individuals more protective of their data (e.g., GDPR), can companies still conduct a thorough internal investigation, even across borders? What about the nuances of attorney-client privilege in different jurisdictions?
  • Argentina’s “notebook case” — a new Lava Jato? How do new bribery laws in Peru and Argentina alter existing risks? With a new president taking office in December, will Mexico’s National Anti-Corruption System finally begin to bite?
  • In the present era characterized by a “new openness” and #MeToo (and a recent, $54 million SEC whistleblower award), how can companies best handle increased reporting and foster more collaboration across departments?

SUB-SAHARAN AFRICA & MIDDLE EAST ROUNDTABLE
Inside Real World Considerations for Third Party Management and “Localizing” Your Compliance Program

Jan 29, 2019 1:30pm - 5:00pm

$600

Speakers

Bill Gordon
Associate General Counsel
Hercules Offshore, Inc. (Washington, DC)

Ana Pinelas Pinto
Partner
Miranda & Associados (Portugal)

What is it about?

(Registration begins at 1:00 pm)

This exclusive workshop offers a unique opportunity to discuss the most pertinent anti-corruption developments across the Middle East and Africa. Specifically, the discussion will revolve around the most challenging aspects for multinationals when doing business in the region, with a particular emphasis on third party due diligence and compliance program localization. The workshop facilitators will provide the context for a candid conversation in an informal and highly practical format most conducive to sharing best practices and benchmarking your compliance program, such as:

  • How to conduct risk-based due diligence in the high-risk African and Middle Eastern context
  • Integrating anti-corruption due diligence processes with other business and legal risk diligence procedures
  • How to identify, interpret and handle beneficial ownership relationships, and how to apply best practices to identify the true owners of your business counterparts
  • Localization requirements in Anglophone vs. Francophone Africa and the Middle East: What internal checks and controls can mitigate your company’s risk of falling afoul of local anti-bribery legislation
  • How can multinationals tackle and overcome the challenge of implementing a global compliance program tailored to the realities on the ground (incl. political system, economic situation, cultural norms)
  • How to choose between and what are the tradeoffs when selecting the resources to best ensure effective oversight of local operations (in-house, local partners, third party service providers, etc.)
  • How on-the-ground compliance champions can contribute to the localization of the program and save both financial and personnel resources
  • How having compliance champions can help create a culture of compliance throughout the enterprise
  • How to sever business ties and conclude contractual relationships with local partners: What is a “clean” break
  • The do’s and don’ts of local content requirements (incl. local skills gap and domestic incapacity): How to get it right
  • How to interpret the perceived shift from global to local providers in the region: Exodus of certain multinationals due to low oil price and ensuing multiplication of multinationals’ local African and Middle Eastern business partners/counterparties