FCPA Exceptions and Affirmative Defenses
Complying With the Requirements for Gifts, Hospitality and Facilitation Payments
Recording of a 75-minute CLE webinar with Q&A
This CLE course will provide guidance to counsel for U.S. companies conducting business internationally on navigating the facilitation-payment exception and affirmative defenses under the Foreign Corrupt Practices Act in order to avoid violations and penalties.
- Exceptions and affirmative defenses
- Facilitating payments
- Gifts and hospitality
- Lessons learned from recent enforcement
- Strategies for complying with requirements of exception/affirmative defenses
- Policies and procedures
- Internal controls
The panel will review these and other key questions:
- What is the scope of permissible facilitation payments? permissible gifts and hospitality?
- What guidance is provided by DOJ advisory opinions and recent enforcement actions?
- What steps can companies take to minimize the risk of violating the exceptions and affirmative defenses for facilitation payments, gifts and hospitality?
Wilmer Cutler Pickering Hale and Dorr
Mr. Holtmeier conducts investigations involving conduct in Europe, Asia, the Middle East, Africa and Latin America and... | Read More
Mr. Holtmeier conducts investigations involving conduct in Europe, Asia, the Middle East, Africa and Latin America and counsels clients facing difficult FCPA issues in a variety of business contexts. He has assisted clients in numerous industries in developing and implementing FCPA compliance programs and advises clients on FCPA problems that arise in mergers and acquisitions and other corporate transactions.Close
James T. Parkinson
He focuses primarily on white collar criminal defense litigation, corporate internal investigations and compliance... | Read More
He focuses primarily on white collar criminal defense litigation, corporate internal investigations and compliance counseling. He has a substantial practice relating to the Foreign Corrupt Practices Act, including international investigations and compliance counseling.Close
Kelli C. McTaggart
Vice President, Associate General Counsel & Chief Ethics and Compliance Officer
She manages the compliance program for all of Time Warner’s domestic and international operations. She oversees... | Read More
She manages the compliance program for all of Time Warner’s domestic and international operations. She oversees the company’s FCPA compliance program, including advising internal clients on FCPA and anti-corruption issues, supervising internal investigations, developing policies, and conducting training.Close