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FCPA Internal Investigations: Preserving the Evidence, Assessing Voluntary Disclosure, and Other Key Elements

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 Tuesday, March 10, 2020

Recorded event now available

or call 1-800-926-7926

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


The U.S. DOJ and the SEC continue to focus on FCPA enforcement. As a result, companies doing business outside the United States continue to be at increased risk of--and must carefully assess the potential for--FCPA violations. In recent years, several companies, including 3M Co., Airbus, and Avianca Holdings, disclosed that they had launched internal investigations into possible violations of the FCPA and other anti-corruption laws.

With companies facing heightened government scrutiny and updated policies from the U.S. Department of Justice, counsel must carefully weigh whether to conduct an internal investigation into suspected violations, how to perform the investigation most cost-effectively, and what to disclose to the government and when.

Listen as our authoritative panel of practitioners explains how to assess whether to conduct an internal investigation of suspected or alleged FCPA violations, reviews critical elements and challenges of the inquiry, 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
    5. Handling potential interests and issues in multiple jurisdictions
  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. Whether and when to disclose an investigation


The panel will review these and other key issues:

  • 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 blocking statutes?
  • What steps can companies take to control costs while ensuring sufficient information has been gathered for a proper internal investigation?


Davis, John
John E. Davis

Member and FCPA/International Anti-Corruption Practice Lead
Miller & Chevalier

Mr. Davis focuses his practice on international regulatory compliance and enforcement issues. He advises on corruption...  |  Read More

Kimberly A. Parker

Wilmer Cutler Pickering Hale and Dorr

Ms. Parker focuses on white-collar criminal matters, internal corporate investigations, and compliance counseling. She...  |  Read More

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