The Foreign Corrupt Practices Act continues to be a top priority for both the US Department of Justice and the US Securities and Exchange Commission. Recent speeches by a series of top-level DOJ officials - including a May 31st speech by Attorney General Eric Holder - confirm that the US focus on anti-corruption efforts will not abate. If anything, the focus will intensify as additional prosecutors join the enforcement team, and the SEC's FCPA Unit starts work in earnest.
At the same time, numerous signatories to the OECD's Convention on Combating Bribery are enhancing their enforcement programs. The United Kingdom's recent Bribery Act, which is expected to become operative later this year, is the latest addition to the growing network of international anti-corruption regimes. In a number of respects, this new Act is wider and more stringent than the FCPA and raises important issues for any commercial organization which carries on business in any part of the UK and therefore subject to UK legal oversight.
As each jurisdiction takes steps to tighten their anti-corruption laws, there is an increased likelihood that companies with international operations may face investigations and enforcement actions in multiple jurisdictions at the same time. Activity in the first half of 2010 demonstrates that this is the new reality. For companies seeking to manage corruption-related risks, the strategy involves rigorous analysis of potential exposures and a compliance program structured to address the risks.
Please join us for a 60-minute webinar addressing these developments and their impact on your international operations. Some of the topics to be addressed include:
- FCPA enforcement activity for the first half of 2010
- what is the scope of the UK Bribery Act and how might it impact your business?
- building a compliance program tuned to multi-jurisdictional legal requirements
Vincent J. Connelly
Zaldwaynaka (Z) Scott