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