FCPA Enforcement Against U.S. and Non-U.S. Executives and Employees

Identifying FCPA Risks and Overcoming Compliance Challenges

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

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Conducted on Tuesday, June 4, 2013

Recorded event now available

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Course Materials

This CLE course will discuss the FCPA enforcement trends against U.S. and non-U.S. executives and the implications for companies. The panel will address the need for risk identification and strategies to minimize those FCPA risks.


Over the past few years, there has been increased enforcement of both U.S. and non-U.S. executives and employees. This expanded focus puts both companies and executives on alert. Resolution of enforcement actions against companies does not always end the government’s investigation of individual executives.

Many non-U.S. executives have worked in countries where corruption is an accepted part of business. With individuals facing heightened government scrutiny, counsel must be able to identify the FCPA risks and put in place policies and procedures to minimize the likelihood of violations.

Two recent decisions from the Southern District of New York provide guidance about the reach of the FCPA and U.S. agencies' ability to pursue enforcement actions against non-U.S. executives.

Listen as our authoritative panel examines recent enforcement trends and actions against both U.S. and non-U.S. executives and employees. The panel will outline how to identify FCPA risks for individual company executives and employees and offer strategies for minimizing those risks.



  1. Recent enforcement
    1. Against U.S. citizens
    2. Against non-U.S. citizens
  2. Identification of risks for individuals and companies (based on individual conduct)
  3. Strategies to minimize risk


The panel will review these and other key questions:

  • What conduct by executives and other employees raises red flags of potential violations for the SEC and Department of Justice?
  • What steps can companies and counsel take to minimize the risk of FCPA violations by non-U.S. executives?
  • What guidance is provided by recent federal district court decisions?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


James G. Tillen
James G. Tillen

Miller & Chevalier

Mr. Tillen has significant experience with every facet of an FCPA enforcement matter, including developing work...  |  Read More

James T. Parkinson
James T. Parkinson


He focuses primarily on white collar criminal defense litigation, corporate internal investigations and compliance...  |  Read More

Lara Covington
Lara Covington

Special Counsel
Schulte Roth & Zabel

She represents individuals and corporations in connection with investigations and enforcement actions involving the...  |  Read More

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