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FCPA in India 2020: Compliance Strategies for India's Unique Cultural and Governmental Intricacies

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, February 5, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course 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 June 2019, Walmart Inc. agreed to pay the DOJ and SEC $282 million to settle allegations that it violated the FCPA for insufficient anti-corruption internal controls in India and other countries. As a result of weak internal controls, "Walmart subsidiaries paid certain third-party intermediaries without reasonable assurances that certain transactions were consistent with their stated purpose or consistent with the prohibition against making improper payments to government officials."

Over the last few years, the SEC and DOJ have brought actions against several companies, including Anheuser-Busch InBev, Oracle, Tyco International, Dow Chemical, and Mondelez International, based on their activities in India. In the current era of 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 for doing business in India
    1. Indian business culture/practices
    2. Defining a bribe
    3. Exposure to a 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 are the lessons of recent SEC and DOJ enforcement efforts impacting 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?


Everson, Jeffrey
Jeffrey (Jeff) Everson, CPA

Senior Manager

Mr. Everson is a CPA, has been with the firm for 15 years, and serves as a Senior Manager.

 |  Read More
Holtmeier, Jay
Jay Holtmeier

Wilmer Cutler Pickering Hale and Dorr

Mr. Holtmeier co-leads the firm's FCPA and Anti-Corruption Group and is a member of the Dodd-Frank Whistleblower...  |  Read More

Keating, Elizabeth
Elizabeth D. Keating

VP, Chief Ethics and Compliance Officer
Gemological Institute of America

Ms. Keating is a successful global ethics and compliance counsel with unique experience building and leading...  |  Read More

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