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Past Event
16 November 2015 - 19 November 2015


  • Laurence Urgenson
    T +1 202 263 3280
  • Kelly B. Kramer
    T +1 202 263 3007

ACI’s 32nd International Conference on the Foreign Corrupt Practices Act

Larry Urgenson and Kelly Kramer will participate in ACI’s 32nd International Conference on the Foreign Corrupt Practices Act on November 16-19, 2015 in Washington DC.

Larry Urgenson will moderate a panel entitled, “Don’t Boil the Ocean” – Right-Sizing Your Internal Investigations: The Top 10 Practical Considerations for Managing the Scope and Costs of Investigating Corruption”. The panel will cover:

  • Determining the scope of your document review, and interview process and analysis
  • Recent USDOJ investigations, enforcement actions and settlements, and what they reveal about right-sizing internal investigations
  • Determining how much you need to spend and how to manage the risk of spiraling costs
  • When and when not to investigate new or peripheral red flags that are discovered over the course of the internal investigation
  • When to stop: How to know when to conclude the investigation
  • Preparing your client for what may lie ahead

Kelly Kramer will speak on an panel that will discuss “Disclosure Case Studies & Hypotheticals – Would You or Wouldn’t You? Changing Your FCPA Self-Disclosure Calculus: Measuring the Benefits of US Cooperation Credit with the Associated Risks of Foreign Enforcement, Detention and Prosecution”. During this practical, interactive session, expert practitioners will take audience members through a number of hypothetical scenarios to discuss whether or not they would disclose under the circumstances. Participants will be able to compare their approaches and benchmark via anonymous audience polling.

  • How recent global enforcement developments should affect your disclosure decision
  • Which factors should drive disclosure
  • Assessing the impact of US disclosures on foreign corruption investigations
  • If and when a disclosure in the US can then be used against you by a foreign government
  • Balancing disclosure obligations while preserving privilege
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