FCPA in India 2016: Compliance Strategies for India's Unique Cultural and Governmental Intricacies

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

Conducted on Tuesday, January 12, 2016

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will provide guidance to counsel for companies doing business in India to develop and implement a Foreign Corrupt Practices Act (FCPA) compliance program. The panel will review recent FCPA enforcement focused on India operations and discuss the unique FCPA challenges for conducting business there.


The number of U.S. companies conducting business in and with India continues to escalate. Though FCPA violations carry severe sanctions and penalties, this rapid growth leaves many companies and their employees unprepared to comply.

FCPA enforcement continues to be a top priority for the DOJ and SEC. In July 2015, Louis Berger International Inc. admitted to FCPA violations and agreed to pay $17.1 million to resolve charges that it bribed officials in India and other countries to get government contracts. Also, Anheuser-Busch InBev NV recently pulled out of a joint venture in India due to potential FCPA violations.

Further, there have been recent legislative efforts within India to combat graft and corruption. In the current era of heightened and robust FCPA enforcement and anti-corruption initiatives in India, companies must develop, implement and monitor comprehensive compliance programs.

Listen as our authoritative panel discusses the risks of doing business in India, conduct that may trigger FCPA violations, working with Indian government agencies, preventative steps to mitigate risk, and strategies for investigations and enforcement.



  1. Risk factors of doing business in India
    1. Indian business culture/practices
    2. Defining a bribe
    3. Exposure to third party you may not control
    4. Reach of the FCPA in India
    5. Working with the Indian government
  2. Preventative steps to mitigate risk in transactions
    1. Internal controls
    2. Education/training adapted to local conditions
    3. Due diligence—all third parties
  3. Investigations and enforcement
    1. Monitoring
    2. Compliance programs—anti-bribery and accounting provisions
    3. Steps if misconduct is suspected


The panel will review these and other key issues:

  • What are the risk factors that make companies conducting business in India vulnerable to possible FCPA violations?
  • What lessons can be learned from recent SEC and DOJ enforcement efforts affecting companies doing business in or with India?
  • What are the best practices for companies to utilize in developing anti-corruption compliance programs and due diligence efforts?


Jay Holtmeier
Jay Holtmeier

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

Elizabeth D. Keating
Elizabeth D. Keating
Vice President, Global Investigations Counsel
Johnson Controls

Ms. Keating is responsible for oversight and supervision of all internal investigations for Johnson Controls, Inc., a...  |  Read More

Michael Stavridis
Michael Stavridis
Ernst & Young

Mr. Stavridis is a US CPA and a South African Chartered Accountant and a Partner in the Fraud Investigation &...  |  Read More

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