The aggressive enforcement of the Foreign Corrupt Practices Act (FCPA) by the Department of Justice and the Securities and Exchange Commission shows no signs of abating, as newly-appointed Administration officials have expressed their commitment to continuing the emphasis of the two prior administrations. The government appears to be poised to continue the FCPA Pilot Program that DOJ’s Fraud Section introduced in April 2016, which resulted in a flurry of settlements over the last year with their attendant billions of dollars in fines and penalties. As the enforcement agencies’ experience prosecuting FCPA violations grows, so too does their level of sophistication and thus, their expectation of companies’ compliance programs. It will no longer suffice to have an FCPA compliance program on paper and periodically train employees about it – the government expects companies operating in higher-risk geographies to actually monitor compliance and to prevent and detect violations. One of the key methods by which companies do this is via anti-corruption internal audits.
The presenters of this webcast are experienced in the design and performance of such anti-corruption audits, as well as in remediating findings arising from such audits. The webinar, while providing an overview of the key considerations of anti-corruption audits, will also address some of the practical challenges facing organizations that may be considering them for the first time, such as:
- Which countries should be included in compliance assessment efforts, and why? How many should be done, and how often?
- Who should lead the audits, and should lawyers be involved? Why? Can an internal audit be performed under privilege?
- When should anti-corruption audits be scheduled, and what should their scope be?
- How can organizations keep audit costs down while getting ‘bang for the buck?’