FCPA Internal Investigations: Latest Developments

Preserving the Evidence, Assessing Voluntary Disclosure and Other Key Elements

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

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Conducted on Wednesday, March 20, 2013

Recorded event now available

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Course Materials

This CLE course will prepare counsel for companies with business in foreign countries to evaluate whether an internal investigation should be conducted into potential Foreign Corrupt Practices Act (FCPA) violations. The panel will review the key elements and challenges involved and outline best practices for conducting the investigation.


With the continued focus on FCPA compliance by the U.S. DOJ and the SEC, companies doing business outside the United States are at increased risk of—and must carefully assess the potential for—FCPA violations.

The DOJ also expanded its enforcement focus to include the prosecution of individuals, which adds another layer of complexity in the investigation process. Further, Dodd-Frank gives whistleblowers additional incentive to report suspected FCPA violations.

With companies facing heightened government scrutiny, counsel must carefully weigh whether to conduct an internal investigation into suspected violations and how to conduct the investigation in the most cost-effective manner.

Listen as our authoritative panel of practitioners explains assessing whether to conduct an internal investigation of suspected or alleged FCPA violations, reviews key elements and challenges of the investigations, and offers best practices for conducting investigations.



  1. To investigate or not to investigate
    1. Determining validity of suspected/alleged FCPA violation
    2. Determining whether an investigation is needed
    3. Scope of investigation
  2. Key elements and challenges
    1. Critical aspects of an efficient investigation
    2. Considerations when doing investigations abroad
    3. How far should the factual inquiry go
    4. Ethical dilemmas and conflicts of interest
  3. Conducting the investigation
    1. What the investigation should look like
    2. Impact of specific industries
    3. Identifying and interviewing employees/witnesses
    4. Privilege issues
    5. Collecting and reviewing documents
    6. Disclosure obligations triggered by investigation


The panel will review these and other key questions:

  • What are the key considerations for counsel conducting internal investigations abroad?
  • What can counsel do to protect privileges and confidential information?
  • What are the best practices to minimize violations of privacy law and the blocking statute?
  • What steps can companies take to control costs while ensuring sufficient information has been gathered for a proper internal investigation?

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


Kimberly A. Parker


Ms. Parker regularly counsels clients on how to develop effective FCPA compliance programs, how to avoid potential...  |  Read More

John E. Davis
John E. Davis

Miller & Chevalier Chartered

He focuses on international regulatory compliance and enforcement issues. He advises on corruption issues around the...  |  Read More

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