FCPA, Export Control, and Economic Sanctions: Enforcement Trends and Compliance

27 February 2013 Dashboard Insights Blog

On January 24, 2013, Foley attorneys Greg Husisian and Christopher Swift briefed the Original Equipment Suppliers Association (“OESA”) Legal Council on recent FCPA, Export Control, and Economic Sanctions enforcement trends. Focusing on anticorruption, munitions, dual-use technologies, and a broad spectrum of new sanctions, the presentation identified enhanced risks for multinational companies that manufacture and export goods around the world and provided practical advice regarding compliance with these complex laws, including a twelve-step program for managing risk and implementing compliance for international operations. Between complex new laws and increasingly aggressive government enforcement, sanctions and export controls investigations are now producing the kind of multimillion dollar civil and criminal penalties long associated with FCPA proceedings.

Greg and Christopher’s two-hour presentation was followed by an intensive ninety-minute question and answer period, with OESA Legal Council members being particularly focused on questions relating to the complex web of new sanctions on Iran and Syria, the recent U.S. Government focus on transactions outside the United States (including those conducted by the foreign subsidiaries of U.S. companies), and the new FCPA compliance guidelines issued in November by the DOJ and the SEC. The presentation and questions underscored the need for multinational companies in the automotive supply chain to stay fully aware of these complex laws and to implement robust compliance and risk management policies and internal controls.

A copy of the presentation the OESA Legal Council, as well as an extensive summary of compliance best practices for multinational companies that operate abroad, is available by clicking on the following links. 

OESA Legal Issues Presentation (PDF)
Compliance for Multinational Corporations (PDF)

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