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

January 31, 2019 11:15am

What is it about?

  • 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