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