Defining and Dealing with “State-Owned” Entities in the FCPA Context

January 24, 2024 12:15pm

Claire Rajan
Allen & Overy

Marianne Ibrahim
Chief Compliance Officer

Jennafer Watson
Director of Ethics & Compliance, Assistant General Counsel

During this session, legal and compliance experts will delve into the unique considerations affecting your compliance policies and protocols, including:

  • What is (and isn’t) a “state-owned” entity, as defined in the FCPA-and the enduring grey areas
  • Applying both ownership interests and level of control tests when determining whether something is “state-owned”
  • Managing the inherent, heightened risks when dealing with state-owned entities
  • Defining “instrumentality” in relation to essential government control, and understanding how/when instrumentalities are more/less important