You need only look at recent headlines to see that the FCPA and other anti-bribery laws continue to present a major risk to corporate America. In a recent survey conducted by the Association of Corporate Counsel, 74% of Chief Legal Officers reported that the number-one issue keeping them up at night is compliance and ethics, with 28% reporting that a regulator targeted their company last year for an enforcement action.
The FCPA enforcement paradigm is shifting. DOJ’s and SEC’s expectations of companies – both in terms of anti-bribery compliance and in responding to bribery-related issues that arise – are becoming more clear. And arguably more is expected.
We invite you to join us for a unique opportunity to hear from three uniquely qualified FCPA professionals what constitutes an effective FCPA compliance program and what the regulators expect from companies that identify bribery problems.
Foley partner David Simon just completed his first year as lead FCPA counsel in an SEC/DOJ-mandated monitorship of a major financial institution, and is an experienced FCPA defense lawyer who has handled FCPA investigations and defended DOJ and SEC enforcement actions all around the world.
Rohan Virginkar has recently rejoined Foley & Lardner after spending several years as a trial attorney at the U.S. Department of Justice’s Criminal Division, Fraud Section, where he was part of the FCPA Unit.
Neuman (“Larry”) Leverett is Vice President and Counsel, Corporate Compliance at Johnson Controls. He leads the company’s global programs to manage anti-corruption and antitrust risks, including overseeing the Third Party Program, internal investigations, and anti-corruption due diligence in connection with mergers and acquisitions.
A light breakfast will be served.
Topics will include:
- Application of the new DOJ FCPA Corporate Enforcement Policy.
- What is an “effective” compliance program? Understanding the different controls needed by different enterprises.
- How are companies translating the regulators’ expectations into reality?
- Insiders’ perspectives on properly applying the DOJ’s “Evaluation of Corporate Compliance Programs,” and satisfying the SEC’s compliance expectations.
- What it is like to be across the table from the DOJ/SEC in an enforcement posture.