Foreign Corrupt Practices Act Compliance: Strategies for an Effective Global Program

Description

The Department of Justice and the Securities and Exchange Commission have ramped up their scrutiny of U.S. companies' interactions with overseas officials and strengthened Foreign Corrupt Practices Act anti-corruption enforcement efforts. Companies must likewise ramp up their compliance efforts.

However, a recent poll of over 1,000 company executives showed that almost one-third of companies do not have a compliance program, despite the dramatic rise in FCPA enforcement.

Companies that do business around the world must establish and implement comprehensive FCPA compliance programs. Compliance programs not only deter FCPA violations but are also a factor in the government’s enforcement analysis—and can mitigate penalties in the case a violation is identified.

Listen as our authoritative panel of experienced attorneys examines the key components of and best practices for developing and implementing an effective FCPA compliance program.

Outline

1. Overview—the FCPA, the current enforcement environment and importance of having a compliance program in place
   1. Consideration under the Sentencing Guidelines
   2. Consideration for SEC under Seaboard Report principles
2. Compliance programs—key components
   1. Assessing risks faced company
   2. Clearly articulated corporate policy
   3. Effective communication of corporate policy
   4. Appropriate structure and resources for compliance program
   5. Training
   6. Reporting system
   7. Dealing with third parties
   8. Appropriate disciplinary procedure
   9. Financial and accounting procedures
   10. Periodic audits
3. Internal controls
   1. Accounting controls
   2. Record-keeping/documentation
   3. Internal audits/monitoring
4. Third party policies/procedures
   1. Review of existing compliance policies and controls
   2. Examination of subsidiaries, joint ventures, other controlled entities
   3. Third-party integrity investigations/due diligence
   4. Customer risk analysis
5. Education
   1. Guidelines for gifts, travel and entertainment of “government officials”
   2. Guidelines for facilitating payments
   3. Training employees
   4. Training agents, joint venture partners
6. Red flags
7. Steps if misconduct is suspected
   1. Investigate
   2. Bring in third party consulting firm
   3. Remedial actions
   4. Self-report?
   5. Cooperate with the government

Benefits

The panel will review these and other key questions:

• What is the government looking for in an FCPA compliance program when it investigates a business?
• What remediation policies should companies consider implementing?
• What are the best practices for companies to utilize in developing anti-corruption compliance programs and due diligence efforts?

Webinar/Teleconference

Strafford webinars/teleconferences offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program).  Please note that our webinars do not feature videos of the presenters.

CLE Credit

Strafford's live seminars qualify for CLE in every state that accredits webinars. They offer you a high quality, cost effective, and convenient CLE option, with no lost travel time or expenses.

More Details >

Our Guarantee

Strafford webinars and teleconferences are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10.