ECONOMIC SANCTIONS and FCPA DUE DILIGENCE

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

January 31, 2019 11:15am

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