Full Event Description
The pace of U.S. and foreign criminal and civil corruption prosecutions against corporation and the size of the penalties has steadily increased since the globalization of FCPA principles by the OECD Convention in 1997. As demonstrated by the recent Siemens, Hewlett-Packard, Innospec, and BAE matters, a single company may be exposed to the risk of investigation and prosecution in multiple jurisdictions at the same time. Prosecution is bad enough, but the mere fact of a global corruption investigation is likely to result in significant, ongoing, and costly collateral consequences, including a drumbeat of damaging publicity, disruption and delay of business transactions, difficulty in retaining and recruiting executives and employees, suspension or temporary debarment from public procurement, delay in filing audited financial statements, and, of course, costly legal bills.
No compliance program is perfect, but a reasonably effective program is a critical tool in mitigating the risk that your company will be caught up in a global investigation. Recent enforcement actions in the U.S., Japan, the U.K., and Germany suggest important elements that should be included in a global anti-corruption compliance program but, to several companies' chagrin, are sometimes neglected or sidelined.
Philip Urofsky, a former FCPA prosecutor and now the head of Shearman & Sterling’s Global Anti-corruption Practice Group and Dan Newcomb, a dean of the FCPA bar, speak on the lessons that can be drawn from recent enforcement actions and how these lessons can be applied in practical, cost-effective ways to mitigate corruption compliance risk.