DOJ Issues New FCPA Guidance and Launches Self-Reporting Pilot Program

The US Department of Justice has announced the creation of a one-year pilot program intended to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties, ranging from reductions in fines to declinations.

On April 5, the Fraud Section of the US Department of Justice (DOJ) issued its “Foreign Corrupt Practices Act Enforcement Plan and Guidance” (Guidance) outlining the following “three steps in [its] enhanced FCPA enforcement strategy”:

  1. The intensification of its investigative and prosecutorial efforts by substantially increasing its FCPA law enforcement resources.

  2. The strengthening of its coordination with foreign law enforcement.

  3. Its implementation of an “FCPA enforcement pilot program” to encourage voluntary disclosure, cooperation, and remediation.[1]

While the first two steps have been championed in prior DOJ press releases and speeches, the third step—the creation of the FCPA enforcement pilot program—is an important development that has the potential to change the voluntarily disclosure calculus in connection with FCPA matters.

The Guidance applies “to organizations that voluntarily self-disclose or cooperate in FCPA matters during the pilot period, even if the pilot thereafter expires.”[2]

Intensification of DOJ’s Investigative and Prosecutorial Efforts

The Fraud Section plans to more than double the size of its FCPA Unit by “adding 10 more prosecutors to its ranks”[3]—a staffing goal that was previously announced by Assistant Attorney General for the Criminal Division Leslie Caldwell at an FCPA conference in November 2015.[4] The Guidance also cites the FBI’s establishment of “three new squads of special agents devoted to FCPA investigations and prosecutions,” a hiring initiative that was announced approximately a year ago.

Strengthening of DOJ’s Coordination with Foreign Law Enforcement

The second part of the Guidance builds on previous statements by senior DOJ leaders that they “are greatly aided by our foreign partners”[5] and “it is safe to say [in 2013] that we are cooperating with foreign law enforcement on foreign bribery cases more closely today than at any time in history.”[6]

FCPA Enforcement Pilot Program—Eligibility and Potential Benefits

The most important part of the Guidance is the Fraud Section’s announcement of a one-year “FCPA enforcement pilot program,” which provides for “mitigation credit” that takes into consideration three essential factors: (1) voluntary disclosure, (2) full cooperation, and (3) remediation. In cases in which the above three factors are met but a criminal resolution is nonetheless warranted, “mitigation credit” can include “up to a 50% reduction off the bottom end of the Sentencing Guidelines fine range, if a fine is sought” and the avoidance of a third-party compliance monitor.”[7] Moreover, the Guidance states that, in appropriate cases, where the above factors are fully satisfied, DOJ “will consider a declination of prosecution.”[8]

Voluntary Self-Disclosure

A company must voluntarily disclose an FCPA violation to the Fraud Section in order to be eligible for the full mitigation credit. As a preliminary matter, the disclosure must be truly voluntary—a disclosure that the “company is required to make, by law, agreement, or contract” would not constitute voluntary self-disclosure for purposes of this pilot.[9] Second, the disclosure must occur “prior to an imminent threat of disclosure or government investigation” and be “within a reasonably prompt time after becoming aware of the offense,” with the burden on the discloser to demonstrate timeliness.[10] Finally, the disclosure must include “all relevant facts known to [the company], including all relevant facts about the individuals involved in any FCPA violation.”[11]

DOJ’s voluntary disclosure requirement follows a recent announcement by the US Securities and Exchange Commission (SEC) that companies subject to FCPA enforcement actions are required to self-report their potential misconduct to be eligible for deferred prosecution agreements and non-prosecution agreements. Full Cooperation

The Guidance sets forth nearly a dozen requirements for companies seeking cooperation credit under the pilot program.[12] Those requirements can be distilled into the following four categories:

  • Disclosure of Relevant Facts: Companies are expected to disclose “all facts relevant to the wrongdoing at issue” on a timely basis, including “all facts related to involvement in the criminal activity by the corporation’s officers, employees, or agents” and “all facts relevant to potential criminal conduct by all third-part[ies].” Disclosure is expected to be “proactive” rather than “reactive,” and facts relevant to the investigation should be voluntarily provided “even when [companies are] not specifically asked to do so.” In addition, disclosures are expected to include “all relevant facts gathered during a company’s independent investigation.”

  • Preservation and Disclosure of Documents: All relevant documents—as well as “information related to their provenance”—are expected to be collected, preserved, and disclosed. This expectation extends to “overseas documents” and important details about those records such as their location and the individuals who discovered them. In some cases, prosecutors may insist that companies provide translations of foreign-language documents. Finally, it is expected that companies will assist with the “third-party production of documents . . . from foreign jurisdictions.”

  • Making Individuals Available for Interviews: Upon request, companies are expected to “mak[e] available for [DOJ] interviews those company officers and employees who possess relevant information,” including—where appropriate and possible—individuals located overseas, as well as those who no longer work for the company.

  • Conducting Transparent and Coordinated Internal Investigations: Companies are expected to provide timely updates about their internal investigations and, where requested, ensure that such investigations do not conflict with those being conducted by the government.

The Guidance notes that “cooperation comes in many forms,” and that the Fraud Section “does not expect a small company to conduct as expansive an investigation in as short a period of time as a Fortune 100 company.”[13]

Remediation

The final requirement is that of “timely and appropriate remediation,” and the following items generally will be required in order for companies to receive remediation credit:

  • Implementation of an Effective Compliance Program: While the criteria depend on the size and resources of the organization, the following factors are normally considered:

    • Whether the company has established a “culture of compliance”

    • Whether the company has sufficient compliance resources

    • The quality and experience of the compliance personnel

    • The independence of the compliance function

    • Whether the company’s compliance program has performed an effective risk assessment and tailored the compliance program based on that assessment

    • How a company’s compliance personnel are compensated and promoted

    • Auditing of the program to assure its effectiveness

    • The reporting structure of compliance personnel within the company

  • Discipline of Culpable Employees: It is expected not only that companies discipline culpable employees, but that they have systems that provide for the possibility of disciplining others with oversight of the responsible individuals.

  • Acceptance of Responsibility and Implementation of Reforms: Companies are expected to recognize the seriousness of the misconduct, accept responsibility for it, and implement reforms to identify and reduce the risk of similar violations.[14]

Credit

Where the above conditions are met but a criminal resolution is warranted, the Fraud Section’s FCPA Unit (1) may accord up to a 50% reduction off the “bottom end” of the Sentencing Guidelines fine range, if a fine is sought; and (2) generally should not require appointment of a monitor if a company has, at the time of resolution, implemented an effective compliance program.

Furthermore, where the same conditions are met, the Fraud Section’s FCPA Unit will consider a declination of prosecution. In doing so, prosecutors must balance the importance of encouraging disclosure against the seriousness of the offense. In assessing the seriousness of the offense, prosecutors are to consider the involvement by executive management in the FCPA misconduct, the size of the ill-gotten gains in relation to the overall revenue of the company, a history of noncompliance by the company, and any prior resolutions by the company with DOJ within the past five years.

Finally, if the company cooperates and remediates, but has not voluntarily disclosed, the Fraud Section’s FCPA Unit may provide partial mitigation credit, but will agree to no more than a 25% reduction off the bottom of the Sentencing Guidelines fine range.[15]

Implications

This Guidance comes after what has been a growing perception that voluntary disclosures have slowed significantly due to a lack of transparency, consistency, and clarity as to what the benefits are, if any, to self-disclosing. Whether the pilot program succeeds in encouraging self-disclosures will likely depend on the perception of companies and defense counsel of the fairness and openness of the application of the criteria in the Guidance.


[1] US Dep’t of Justice, Memorandum from Andrew Weissmann titled “The Fraud Section’s Foreign Corrupt Practices Act Enforcement Plan and Guidance” (Apr. 5, 2016) (Guidance)

[2] Guidance at 3.

[3] Id. at 1.

[4] Stephen Dockery, “US Justice Dept. Boosting Foreign Corruption Staff,” Wall Street Journal (Nov. 17, 2015)

[5] US Dep’t of Justice, “Assistant Attorney General Leslie R. Caldwell Speaks at American Conference Institute’s 31st International Conference on the Foreign Corrupt Practices Act” (Nov. 19, 2014)

[6] See id.; see also US Dep’t of Justice, “Acting Assistant Attorney General Mythili Raman Delivers Keynote Address at the Global Anti-Corruption Congress” (June 17, 2013)

[7] Guidance at 8.

[8] Id. at 9.

[9] Id. at 4.

[10] Id.

[11] Id.

[12] Id. at 5-6.

[13] Id. at 6.

[14] Id. at 7-8.

[15] Id. at 8-9.

FIVE MINUTES ON… Anti-Bribery and Corruption Laws in Europe

Anti-bribery and corruption has been a hot topic in the US for almost 40 years. The topic has historically however received much less attention within Europe. That is now changing as Europe is beginning to catch up and many European countries have already implemented anti-bribery laws much stricter than those in the US. Recent events have put the topic back on the agenda and we can expect further debate on the effectiveness and efficacy of enforcement in Europe.

The levels of perceived corruption within Europe are generally quite good. Transparency International publish an annual Corruptions Perceptions Index which shows the perceived levels of corruption in 175 countries globally. In its 2014 report, the average score across the EU and Western Europe was 66 (with 0 being highly corrupt and 100 being very clean), much better than the global average of 43. Even those countries with the lowest scores in the EU and Western Europe, being Greece, Romania and Italy, had a score of 43, consistent with the global average. Seven of the top 10 least corrupt countries are actually in Europe (Denmark, Finland, Sweden, Norway, Switzerland, Netherlands and Luxembourg).

Over the last five or so years, countries within Europe have been overhauling their existing, in many cases insufficient, anti-bribery regimes and some countries have implemented anti-bribery laws for the first time. We consider some of the specific regimes below along with their differences and similarities. The majority, if not all, are actually stricter than the laws in the US. The differences of the laws in Europe to the laws in the US have been somewhat of a surprise to many organisations who currently comply with the laws in the US and who don’t necessarily realise that they now need to enhance their practices to comply with more stringent regimes.

What’s Been Happening Across the Pond?

In the US, the Foreign Corrupt Practice Act (FCPA) came into force on 19 December 1977. The FCPA criminalises the paying or offering of a bribe to a foreign official, although the public official themselves do not commit an offence by receiving the bribe. The FCPA requires organisations to have accounting and other controls in place to prevent and detect bribery, but does not specifically require broader anti-bribery programmes. As well as US organisations, the FCPA has extraterritorial reach and catches any other organisation that uses any means of US commerce, including mails, emails, faxes, bank transactions, and similar acts.

Top of the Class: the Uk

Much of the change in approach within Europe and indeed further afield has arguably been led by the introduction in the UK of the Bribery Act 2010 (Bribery Act), which came into force on 1 July 2011, and which is thought to be the strictest anti-bribery legislation in the world.

Similarities between the FCPA and the Bribery Act Differences between the FCPA and the Bribery Act

Territorial Reach

The Bribery Act has a wide territorial reach. It extends not only to offences committed in the UK but also to offences committed outside the UK where the person committing them has a close connection with the UK by virtue of them being a British national or ordinarily resident in the UK, a body incorporated in the UK or a Scottish partnership. For corporations, the corporate offence in the Bribery Act extends to UK as well as non-UK organisations that carry on business or part of a business in the UK. So, for example, a Spanish company that exports to the UK can be in breach of the corporate offence for bribery occurring in Spain, even though that bribery does not involve any UK connected person.

Penalties

The penalties available for breaches of the Bribery Act are severe. They include an unlimited fine, up to 10 years in prison, and orders for directors to be disqualified. Companies can also be prohibited from public procurement and the proceeds from the bribe, for example the monies gained from a contract obtained through corruption, can be confiscated. Penalties under FCPA are slightly less severe with fines being capped to US$2 million (for corporations) and imprisonment for individuals being limited to a maximum of five years.

All Bribes Are Caught, Even Business-to-Business!

Arguably the single most important difference between the Bribery Act and the FCPA is that the Bribery Act prohibits the offering or receiving of a bribe and the bribery of Foreign Public Officials. Unlike the FCPA, the Bribery Act therefore captures private (business to business) bribery and also makes it an offence to receive a bribe as well as pay/offer to pay one. Directors and senior managers can also be found guilty of an offence if their organisation commits one of these offences with their consent or connivance.

Facilitation Payments

Facilitation Payments are payments made to expedite or secure the performance of a “routine government action”. The FCPA expressly authorises such payments. In the UK, such payments are prohibited under the Bribery Act.

The Corporate Defence

The Bribery Act also introduces a corporate offence of failing to prevent a bribe being paid, for which it will be a defence for an organisation to show that it has “adequate procedures” in place to prevent such bribery. Guidance produced by the UK Ministry of Justice explains that these “adequate procedures” need to be guided by six principles: Top-level commitment; Risk assessment; Proportionate procedures; Due diligence; Communication (including training) and Monitoring and review. As stated above, FCPA only requires accounting and other controls to prevent and detect bribery, nothing broader.

Other EU Member States

Most EU Member States have enacted anti-bribery laws with heavy fines. When compared to the Bribery Act, however, such laws are generally more limited in scope and tend to focus on bribery of public officials. Most are however at least consistent with FCPA.

In France, most of the French anti-corruption provisions relevant to businesses are laid down in the French Criminal Code and relate to both the public and private sector and both the offeror and the recipient. Like the UK, the law in France also has an extraterritorial reach and will interestingly apply amongst other situations, where the victim of the bribe is a French national. Penalties for breach of French laws include imprisonment for, in some cases, up to 15 years and financial penalties including, for companies, fines of, in some cases, up to €5 million or twice the amount of the proceeds stemming from the offence. Unlike the UK, there are in France, however, no legal requirements for implementing preventive procedures.

Germany’s anti-bribery laws are contained in the Criminal Code, which prohibits offering, paying or accepting a bribe in domestic or foreign transactions. Separately, civil liability can, if certain criteria are met, attach to companies for offences committed on their behalf due to the Administrative Offences Act. Owners/managers can also be found liable in certain situations. Penalties include five years’ imprisonment (10 years’ imprisonment in severe cases involving a member/official of a public body), a criminal fine and confiscation of monies obtained from the bribe. The Criminal Code also applies to offences committed abroad. One of the key cases to be enforced in Germany was that against Siemens AG, who paid German authorities almost €600 million in fines after they were investigated for paying bribes to secure public-works contracts in a number of countries. This was in addition to fines paid in the US for breaching FCPA.

In the Netherlands, anti-corruption and bribery laws are predominantly aimed at attempts to bribe public officials. Unlike the UK, Dutch law has relatively limited jurisdictional reach. For example, a foreign non-Dutch company that has committed acts of bribery of a non-Dutch foreign official outside the Netherlands is not subject to the criminal laws of the Netherlands. The maximum penalty under Dutch law is a fine of €740,000 for each case of bribery and for individuals, imprisonment for four years (one year for private commercial bribery) and a fine of up to €74,000.

Outlook

While most Member States have clearly improved their anti-bribery regimes in recent years, what seems to be the biggest hurdle is insufficient enforcement and the considerable differences in the enforcement levels across Europe, in particular when it comes to bribery abroad. Relying on the UK (or the US) will soon stretch the already limited resources that individual countries can bring to bear. It seems that the European Union itself will take action in the foreseeable future. Certainly there would be jurisdictional concerns as regards the criminal aspects for individuals, but the Commission’s war on cartels has shown that it is well-suited to enforcing policy. Currently, however, the Commission contends itself with issues in a biannual report on corruption in each Member State.

Given the extra-territorial reach discussed above, European businesses need to make sure that they are compliant with all the different antibribery laws that could affect their business. This is not only the laws in their own countries, but also the laws abroad. Many organisations acting internationally and globally are seeking compliance with the Bribery Act as compliance with the Bribery Act should be sufficient to also achieve compliance with any other anti-bribery legislation.

© Copyright 2015 Squire Patton Boggs (US) LLP

Think Tanks Ask Supreme Court to Clarify Definition of “Foreign Official” in FCPA (Foreign Corrupt Practices Act)

Katten Muchin Law Firm

Two think tanks, the Washington Legal Foundation and the Independence Institute, have filed anamicus brief in the Supreme Court on behalf of petitioners Joel Esquenazi and Carlos Rodriguez, who were recently convicted of violating the Foreign Corrupt Practices Act (FCPA). The amiciseek clarity of the definition of “foreign official” in the FCPA.  The FCPA prohibits certain persons or entities, including US businesses, from paying a “foreign official” for the purpose of obtaining or retaining business. The FCPA defines “foreign official” to include “any officer or employee of a foreign government or any department, agency, or instrumentality thereof.”

Esquenazi and Rodriguez were executives of Terra Telecommunications Corp., a Florida company that purchased phone time from foreign vendors and resold the time to US customers. Terra conducted business with Haiti-owned vendor Telecommunications D’Haiti S.A. (Haiti Teleco). Prosecutors argued that Esquenazi and Rodriguez made payments to Haiti Teleco officers to obtain lower rates. To determine whether Haiti Teleco was an “instrumentality” under the FCPA, the trial court instructed the jury to consider whether the company “provided services to the citizens and inhabitants of Haiti,” and whether it was majority owned by the Haitian government. Defendants were convicted, and Esquenazi was sentenced to 15 years’ imprisonment and Rodriguez received seven years’ imprisonment. The US Court of Appeals for the Eleventh Circuit affirmed, finding that an “instrumentality” is “an entity controlled by the government of a foreign country that performs a function the controlling government treats as its own,” and setting forth a list of factors.

Amici contend that the business community needs concrete guidance in this undeveloped area. They argue that the Eleventh Circuit’s definition is overly broad because (1) Haiti Teleco was never designated a government entity; (2) Haiti Teleco issues common stock, and the government was not an initial stockholder; and (3) Haiti Teleco, as a telephone service provider, does not perform a traditional government function.

Brief for Esquenazi and Rodriguez as Amici Curiae Supporting Petitioners, Esquenazi, et al. v. U.S., Sup. Ct. No. 14-189 (Aug. 14, 2014).

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Register for ABA's National Institute on International Regulation and Compliance: FCPA, Economic Sanctions & Export Control

FCP14_250x250

For the first time ever, the American Bar Association is putting together an inaugural comprehensive program on the FCPA, economic sanctions, and export control.  Led by the Criminal Justice Section and its Global Anti-Corruption Committee, and co-sponsored by the Business Law and International Law Sections, the ABA National Institute on International Regulation and Compliance is a three-day program (October 1-3) in Washington, DC tackling some of the most pressing challenges in cross-border regulations affecting in-house and outside business and transactional lawyers, litigators, investigators, compliance professionals, and forensic examiners, as well as their organizations.

Attracting many of the country’s leading thought leaders and practitioners in their respective fields – and drawing from the membership of all three Sections – the Institute is anchored by an exceptionally strong faculty with deep knowledge of, and experience in, their respective topics.  In addition, the Institute benefits from the participation of a cross-section of government and former government lawyers, who are important contributors to the Institute’s program-content dialogue.  So come be a part of an important, cutting-edge conference with many benefits, including:

  • Fair and balanced program content targeted at both experienced and less experienced professionals in different legal fields
  • Satisfying your state bar legal ethics requirement
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Register today!

2nd Annual Canadian and Global Anti-Corruption Compliance – February 20-22, 2013

The National Law Review is pleased tobring you information regarding the upcoming 2nd Annual Canadian & Global Anti-Corruption Compliance Conference:

Key Topics
  • Create and manage an anti-corruption compliance program with Scotiabank
  • Assess anti-corruption enforcement trends in Canada and globally with Weatherford International
  • Conduct prompt and effective internal investigations with Magna International
  • Strengthen ongoing employee compliance training programs with Halliburton
  • Promote a culture of ethics within the organization with Teekay Corporation
Key Features
  • 2 Pre-Conference Workshops on February 20, 2013
  • Pre-Conference Workshop A: Expand and Strengthen your Global Compliance Program led by Brent Molesky, Vice President of Legal at Talisman Energy and Frank McShane, Manager, Corporate Responsibility & Ethics at Talisman Energy
  • Pre-Conference Workshop B: Conduct Thorough Due-Diligence for Third Parties led by Hentie Dirker, Regional Compliance Officer at Siemens Canada

Event Focus 

Given the escalating pressure from the global community for the Royal Canadian Mounted Police (RCMP) to strengthen their bribery and anti-corruption enforcement, it is key for any cross-border Canadian company to ensure full compliance with both Canadian and global laws.

The marcus evans 2nd Annual Canadian & Global Anti-Corruption Compliance Conference will build upon the inaugural through expanding on issues of Canadian and global anti-corruption enforcement.

By attending this second annual conference, delegates will be able to avoid the risk of fines and investigations through implementing critical bribery and anti-corruption internal controls as well as implement effective compliance programs and improve ongoing employee training. Attendees will walk away from this conference with an improved understanding of risk and how to streamline internal processes and procedures to ensure compliance within companies expanding business both in Canada and globally.

Attending This Conference Will Enable You To:

1. Review the regulatory environment and enforcement trends
2. Develop policies for internal controls for anti-corruption
3. Assess areas of risk within an organization
4. Deal with internal and governmental investigations

Industry leaders attending this conference will benefit from a dynamic presentation format consisting of workshops, panel discussions, and industry-specific case studies that provide accurate, real-world knowledge. Attendees will experience highly interactive conference sessions, 10-15 minutes of Q&A time after each presentation, 4+ hours of networking, and exclusive online access to materials post-event.

2nd Annual Canadian and Global Anti-Corruption Compliance – February 20-22, 2013

The National Law Review is pleased tobring you information regarding the upcoming 2nd Annual Canadian & Global Anti-Corruption Compliance Conference:

Key Topics
  • Create and manage an anti-corruption compliance program with Scotiabank
  • Assess anti-corruption enforcement trends in Canada and globally with Weatherford International
  • Conduct prompt and effective internal investigations with Magna International
  • Strengthen ongoing employee compliance training programs with Halliburton
  • Promote a culture of ethics within the organization with Teekay Corporation
Key Features
  • 2 Pre-Conference Workshops on February 20, 2013
  • Pre-Conference Workshop A: Expand and Strengthen your Global Compliance Program led by Brent Molesky, Vice President of Legal at Talisman Energy and Frank McShane, Manager, Corporate Responsibility & Ethics at Talisman Energy
  • Pre-Conference Workshop B: Conduct Thorough Due-Diligence for Third Parties led by Hentie Dirker, Regional Compliance Officer at Siemens Canada

Event Focus 

Given the escalating pressure from the global community for the Royal Canadian Mounted Police (RCMP) to strengthen their bribery and anti-corruption enforcement, it is key for any cross-border Canadian company to ensure full compliance with both Canadian and global laws.

The marcus evans 2nd Annual Canadian & Global Anti-Corruption Compliance Conference will build upon the inaugural through expanding on issues of Canadian and global anti-corruption enforcement.

By attending this second annual conference, delegates will be able to avoid the risk of fines and investigations through implementing critical bribery and anti-corruption internal controls as well as implement effective compliance programs and improve ongoing employee training. Attendees will walk away from this conference with an improved understanding of risk and how to streamline internal processes and procedures to ensure compliance within companies expanding business both in Canada and globally.

Attending This Conference Will Enable You To:

1. Review the regulatory environment and enforcement trends
2. Develop policies for internal controls for anti-corruption
3. Assess areas of risk within an organization
4. Deal with internal and governmental investigations

Industry leaders attending this conference will benefit from a dynamic presentation format consisting of workshops, panel discussions, and industry-specific case studies that provide accurate, real-world knowledge. Attendees will experience highly interactive conference sessions, 10-15 minutes of Q&A time after each presentation, 4+ hours of networking, and exclusive online access to materials post-event.

2nd Annual Canadian and Global Anti-Corruption Compliance – February 20-22, 2013

The National Law Review is pleased tobring you information regarding the upcoming 2nd Annual Canadian & Global Anti-Corruption Compliance Conference:

Key Topics
  • Create and manage an anti-corruption compliance program with Scotiabank
  • Assess anti-corruption enforcement trends in Canada and globally with Weatherford International
  • Conduct prompt and effective internal investigations with Magna International
  • Strengthen ongoing employee compliance training programs with Halliburton
  • Promote a culture of ethics within the organization with Teekay Corporation
Key Features
  • 2 Pre-Conference Workshops on February 20, 2013
  • Pre-Conference Workshop A: Expand and Strengthen your Global Compliance Program led by Brent Molesky, Vice President of Legal at Talisman Energy and Frank McShane, Manager, Corporate Responsibility & Ethics at Talisman Energy
  • Pre-Conference Workshop B: Conduct Thorough Due-Diligence for Third Parties led by Hentie Dirker, Regional Compliance Officer at Siemens Canada

Event Focus 

Given the escalating pressure from the global community for the Royal Canadian Mounted Police (RCMP) to strengthen their bribery and anti-corruption enforcement, it is key for any cross-border Canadian company to ensure full compliance with both Canadian and global laws.

The marcus evans 2nd Annual Canadian & Global Anti-Corruption Compliance Conference will build upon the inaugural through expanding on issues of Canadian and global anti-corruption enforcement.

By attending this second annual conference, delegates will be able to avoid the risk of fines and investigations through implementing critical bribery and anti-corruption internal controls as well as implement effective compliance programs and improve ongoing employee training. Attendees will walk away from this conference with an improved understanding of risk and how to streamline internal processes and procedures to ensure compliance within companies expanding business both in Canada and globally.

Attending This Conference Will Enable You To:

1. Review the regulatory environment and enforcement trends
2. Develop policies for internal controls for anti-corruption
3. Assess areas of risk within an organization
4. Deal with internal and governmental investigations

Industry leaders attending this conference will benefit from a dynamic presentation format consisting of workshops, panel discussions, and industry-specific case studies that provide accurate, real-world knowledge. Attendees will experience highly interactive conference sessions, 10-15 minutes of Q&A time after each presentation, 4+ hours of networking, and exclusive online access to materials post-event.