FCPA Compliance Audits: Lessons From Recent Investigations

Monitoring and Improving the Effectiveness of FCPA Compliance Programs

Recording of a 90-minute CLE webinar with Q&A


Conducted on Thursday, July 14, 2016

Recorded event now available

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Program Materials

This CLE webinar will provide guidance to counsel and internal audit departments for U.S. companies of all sizes doing business outside the U.S. for planning and executing internal audits that test effective compliance with the Foreign Corrupt Practices Act (FCPA) during a period of increasingly intense enforcement by the DOJ and SEC.

Description

The DOJ and SEC continue to ramp up enforcement of the FCPA. Investigations and significant settlements consistently underscore the need for robust and comprehensive compliance programs, which include periodic audits to detect and prevent violations. For example, in 2015 the SEC reached an agreement with one of the world’s largest tire manufacturers to settle charges of FCPA violations. Under the agreement the tire manufacturer agreed to pay more than $16 million but the SEC did not impose any civil penalty, stressing the manufacturer’s self-reporting of the violation, cooperation with the investigation, and prompt remedial actions.

Similarly, a defense contractor agreed to pay $9.5 million to settle the SEC charges last year that contractor violated the FCPA by bribing government officials with gifts and personal travel. The $9.5 million settlement included disgorgement of $7.53 million and a $1 million penalty. The defense contractor’s self-reporting and cooperation with the investigation were reflected in the lower penalty. The SEC and DOJ joint guidance on having a risk-specific FCPA compliance program is also instructive.

Under this intensified spotlight, counsel and internal audit departments of U.S. companies of all sizes involved in international business must monitor and evaluate the effectiveness of FCPA compliance implementation to avoid government investigations and penalties. Thorough and ongoing internal audits are essential to minimize the risks of FCPA violations.

Listen as our authoritative panel reviews the essential components of an effective FCPA audit, identifies troublesome FCPA compliance audit issues, and offers strategies for overcoming audit challenges and executing an effective and cost-efficient audit.

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Outline

  1. Importance of FCPA audits and risk assessments
    1. Core elements of an anti-corruption compliance program
    2. General parameters of an anti-corruption audit
    3. Risks associated with failure to conduct audit/risk assessment
  2. Forensic examination of anti-corruption compliance
    1. Establishing methodology
    2. Common corruption and fraud schemes
    3. Recommendations for improving financial accounting controls and procedures
  3. Challenges and risks of anti-corruption compliance reviews
    1. Identifying challenges
    2. Strategies for overcoming challenges

Benefits

Our panel will review these and other key issues:

  • What are the essential components of an effective FCPA audit?
  • What strategies are available to overcome troublesome audit challenges?
  • What can be learned from recent DOJ/SEC investigations and settlements?
  • What steps can counsel take to guide clients and companies in executing cost-efficient audits?

Faculty

Sulaksh Shah, CPA, CFE, CFF
Sulaksh Shah, CPA, CFE, CFF
Partner, Forensics
PricewaterhouseCoopers

Mr. Shah has approximately 16 years of public accounting experience. His practice focusses on anti-corruption/FCPA...  |  Read More

James Gargas, MAcc, CPA, CFF, CFE
James Gargas, MAcc, CPA, CFF, CFE
Director, Forensics
PricewaterhouseCoopers

Mr. Gargas has more than a decade of specialized anti-corruption and forensic accounting experience. His practice...  |  Read More

David A. Wilson
David A. Wilson

Partner
Thompson Hine

Mr. Wilson focuses on complex civil litigation, internal and government investigations, and securities enforcement...  |  Read More

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