When Things Go Sideways: From Incident Report to Internal Investigation to Voluntary Disclosure

February 1, 2017 12:00pm

Elliot J. Burger
Director, Global Compliance, Legal Counsel
ATS Automation Tooling Systems Inc. (Cambridge, ON)

Milos Barutciski
Bennett Jones LLP (Toronto, ON)

Thaddeus McBride
Bass Berry (Washington, DC)

An interactive panel comprised of experienced in-house and external counsel will use a hypothetical scenario to walk through the paces from discovery of potential non-compliance through preliminary assessment and investigation to the decision to make a voluntary self-disclosure. The speakers will address multi-agency issues, including export controls, ITAR/CGD and sanctions issues, as well as the strategic and tactical considerations when working in multiple jurisdictions. Issues to be examined will include:

  • Responding to red flags and irregularities and when they warrant an internal investigation
  • Appropriately scoping the internal investigation
  • Multi-jurisdictional exposure and coordination in a global organization
  • Agency guidelines, expectation and requirements for voluntary disclosures (BIS/DDTC/OFAC and GAC/CBSA/CGD/RCMP)
  • New Canadian CGD 3-day disclosure requirement for actual or potential security breach