You need only look at recent headlines to see that the FCPA continues 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.
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.
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.
Grant Thornton partner Kevin Bennett is the practice leader for the Forensic Advisory Services (FAS) practice of Grant Thornton LLP in Minneapolis. He regularly presents the results of his FCPA investigations to the SEC and DOJ, and works with clients to respond to the Government’s expected remediation and to enhance the company’s ethics and compliance programs.
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.
• An insider’s perspective on properly applying the DOJ’s “Evaluation of Corporate Compliance Programs,” and satisfying the SEC’s compliance expectations.
