Big Brother Gets Better Glasses: FERC Enhances Its Market Surveillance Tools

In a concerted effort to enhance its ability to monitor energy markets for possible anti-competitive or manipulative conduct, FERC has undertaken a number of separate initiatives to strengthen its market surveillance capabilities over electric power and natural gas markets.  Among the areas of focus, FERC has been especially keen on obtaining data and market information on a real-time, or near real-time, basis, which is in contrast to FERC’s traditional collection of data through quarterly or annual reports submitted well after-the-fact.  FERC has also been intent on gathering data outside of organized wholesale electric markets.

These initiatives include:

  • On February 16, 2012, FERC Chairman Jon Wellinghoff announced the creation of a new Division of Analytics and Surveillance to the Office of Enforcement.  Described by the Chairman as staffed with “geeks and wonks”, the Division is intended to provide continuous, real-time market surveillance and data analysis of physical gas and electric power markets and of related financial products.  The Division also is intended to develop and implement surveillance tools to detect potential market manipulation, anticompetitive behavior, and other anomalous activity.
  • Beginning in August 2012, FERC enacted a rule to require Regional Transmission Organizations (RTO) and Independent System Operators (ISO) to electronically deliver to FERC non-public data on a rolling basis, seven days after creation.  Specifically, FERC requires RTOs and ISOs to provide: market participant names and pricing points; virtual offers and bids; capacity market offers, awards, and prices; marginal cost estimates; financial transmission rights, or FTR, data; pricing data for interchange transactions; supply offers and demand bids; energy and ancillary services awards; resource output; day-ahead generation and load shift factors associated with constraints; internal bilateral contracts; and uplift charges and credits.  FERC allowed a phased implementation, with only certain data required August 2012, leading up to full implementation by February 2013.  This data collection is intended to supplement ongoing market monitoring efforts by the RTOs’ and ISOs’ market monitors.
  • FERC has also taken efforts to enhance its more traditional forms of reporting, including extending FERC’s Electric Quarterly Report (EQR) requirements to non-public utility entities that make sales above a 4,000,000 MWh threshold under Section 220 of the Federal Power Act (FPA).  These non-public utility entities—which generally consist of governmentally-owned entities, such as federal power marketing administrations, municipal utilities, public utility districts, and coops—have traditionally been exempt from FERC’s EQR filing requirements.  In the Energy Policy Act of 2005, Congress granted FERC increased authority over these entities in order to improve market transparency, as non-public utility entities represent large portions of the market, particularly in areas of the country outside of organized markets.  In the same order, FERC also increased the amount of data required of all EQR filers to include individual trade dates, whether a transaction was reported to an index publisher, the broker or exchange used for a transaction, and e-Tag IDs associated with individual transactions.  In a separate order issued in February 2012, FERC also indicated it will consider requiring EQR filers to report electric “buy-sell” transactions, termed by FERC as “simultaneous exchanges”.
  • FERC is also in the process of considering a rule that proposes to require theNorth American Electric Reliability Corporation (NERC) to provide FERC staff with access to the complete set of non-public e-Tag data.  (Notably, NERCresponded to the Commission’s proposal by noting that other entities, and not NERC, maintained the desired e-Tag information.)  When viewed in conjunction with the new requirement to report e-Tag IDs in the EQRs, it is clear that FERC intends to associate the broader set of e-Tag data with parties’ transaction reports in an effort to understand how power is transacted and scheduled.
  • Finally, on October 15, 2012, FERC Staff issued a set of proposed metrics that would compare the performance of market performance in areas outside of organized wholesale electric markets with performance in organized markets.  As part of this effort, FERC Staff issued a new report, FERC-922, that would collect information from utilities outside of organized markets.  Requested information includes price data and information relating to reliability, transmission planning, requests for service, and system capacity.  Staff stated it will use this information to help develop a common set of metrics for both RTO/ISO markets and non-RTO/ISO markets, and for evaluating market performance thereafter.  FERC Staff noted that it could not require many non-public utility entities to provide such information but requested such entities to comply as part of “a voluntary and collaborative process”.

Taken as a whole, these efforts show an agency intent on gaining a deeper and more granular perspective on energy markets and a better understanding of how those markets function day-to-day.

© 2012 Bracewell & Giuliani LLP

Michigan Zaps Zappers – Cash Business Owners Beware!

The National Law Review recently featured an article by Paul L.B. McKenney of Varnum LLP regarding Cash Business Owners in Michigan:

Varnum LLP

The proverbial “second set of books” cat and mouse game with taxing authorities now reflects the fact that most point-of-sale, or POS, bookkeeping is done electronically.  Michigan recently joined numerous other jurisdictions by enacting tax enforcement spawned legislation making the sale, purchase, installation, transfer or mere possession of any “zapper” software subject to a felony.   Zappers are also known as automated sales suppression devices.  Michigan’s statute contains a mandatory minimum of one year incarceration and severe monetary sanctions. See MCLA § 750.411w.  The statute defines a zapper as a software program, however accessed or possessed, that “falsifies the electronics records of electronic cash registers and other point-of-sale systems, including, but not limited to transaction data and transaction reports.”  MCLA § 750.411w(4)(a). In essence it creates a second set of books, albeit electronic. While the sole purpose of zappers is tax evasion, the prosecution does not have to prove intent, merely use, sale or possession. The zapper software is typically run off a USB thumb drive rather than residing on the computer’s hard drive to avoid leaving evidence of its use.  However, as noted below, there is a readily identifiable electronic trail.  Zappers have been quietly marketed by freelancing IT types and certain cash register sales people.

A not uncommon example illustrates what a zapper does.  Assume a restaurant or other cash receipts business grosses $250,000 per month and is highly profitable.  A zapper software “entrepreneur” visits the restaurant early in the month and is told precisely what recorded cash bank deposits are as well as credit card charges totals by day.  Alternately, the peddler may sell a USB drive and also provide needed technical support. Assume reported sales total $200,000 and there is $50,000 of unreported cash, or “skim.”  The zapper software will quickly and accurately modify the sales records a) by transaction b) by day c) to the penny resulting in the credit card charges and cash deposits equaling what is reported on the books.  Thus a traditional audit will find that everything appears to be in order, at least until someone finds evidence of the zapper.

Zappers represent significant lost sales tax and other tax dollars to states.  For example, three years ago California estimated zappers at restaurants cost that state $2,800,000,000 in receipts and the corresponding New York estimate was $1,700,000,000.  See “State governments target tax-cheating software,” Bloomberg Businessweek, April 3, 2012.  In an era of record state fiscal problems, this is real money.

The recent Michigan legislation is effective as of August 29, 2012.  It is patterned after  another enforcement problem the Michigan Department of Treasury encountered and overcame, false cigarette tax stamps.  The Michigan Treasury was hemorrhaging cash because of cigarettes that were brought in from out of state and counterfeit Michigan stamps were purchased on a flourishing underground market.  The Department of Treasury urged the legislature to adopt legislation that the mere possession of cigarettes with counterfeit stamps required a minimum prison term.  Legislation followed, the minimum mandatory jail time virtually ended the fake stamp problem overnight and Treasury receipts from  cigarette taxes swelled.

Economic Sanctions Too

The zapper legislation has teeth.  In addition to the one-year minimum mandatory term, there is a fine of up to $100,000.  However, from a monetary perspective, there is another more costly provision with which requires disgorgement of “all profits associated with the sale or use of …” a zapper.  In the above example, if the skim is $50,000 a month, then $600,000 a year is subject to forfeiture.  The offending party is also responsible for all Michigan sales, withholding and other taxes, penalties and interest.  These other levies include the corporate income tax and  individual income tax.  Typically cash businesses that use zappers, such as restaurants and retailers selling small dollar amount items, also pay employees all or some of their wages in cash “under the table” and/or purchase food or inventory.

Zapper programs originated in Europe and migrated first to Quebec in North America.  They came from jurisdictions where there were value added taxes.  The Internal Revenue Service has taken certain steps to target businesses that might employ zappers, and the State of Michigan has taken notice.  It should be pointed out that Michigan’s vigorous criminal and civil penalty regime is separate and distinct from the Internal Revenue Service, which is also free to pursue the same individual and business.  There is an exchange of information agreement between the Internal Revenue Service and the Michigan Department of Treasury.

Zapper’s Electronic Fingerprints and Enforcement

Those selling zappers to business owners tout that it leaves no electronic fingerprints, and thus is invisible to the IRS and other law enforcement agencies. That dog don’t hunt.  The reality is that zappers leave telltale electronic fingerprints, and the IRS and other agencies have sophisticated criminal techies who can readily check a computer system and flag evidence of a zapper.

How have the IRS and Michigan uncovered businesses running zappers?  A secret ceases to be secret when two or more people know about it.  When the owner, the manager of a restaurant or store, the zapper software peddler and others, such as the controller or bookkeeper, key employees at the restaurant, at least one or more people at each location, etc. know about the zapper, only one needs to talk.  Somebody may have reason to talk, such as a problem with the DEA, IRS, FBI or other law enforcement agency and will readily give up the business owner in exchange for no prosecution or a reduction in charges or sentencing.  For example, a metro Detroit freelance IT salesman peddling zappers to bars and restaurants was discovered when a party with law enforcement issues named him.  That salesman, in exchange for an extremely lenient sentence,  in turn identified and cooperated with Federal law enforcement in prosecuting numerous customers for tax evasion.  Some of his customers went to jail. The IRS and other federal and state agencies are seasoned veterans of how to play that game most effectively.

Reality

Those who raid businesses with search warrants typically take away computers, hard drives, USB thumb drives, and other hardware for inspection by highly sophisticated technicians.  What does a cash business owner face if his or her business is raided by the State Police or other tax or  law enforcement personnel and evidence that a zapper has been applied to the electronic books is uncovered?  A plethora of problems.  A short, non-inclusive list includes:

  1. The new Michigan legislation and its mandatory jail time and economic sanctions;
  2. Michigan criminal sanctions for various false returns as well as associated civil tax liabilities, fraud penalties and other penalties and interest;
  3. IRS criminal issues including, a five year evasion felony per year and a three year max for false statements on a tax return,
  4. Myriad IRS civil liabilities for income tax and payroll taxes and associated penalties as well as interest, compounded daily, and
  5. If there is fraud, then there is no civil statute of limitations in tax.  The IRS and Michigan can and do go back many, many years.

In a well-publicized local zapper case,  the owner of the LaShish chain of thirteen suburban Detroit restaurants  and his wife were found by the IRS with zapper software that underreported over $16,000,000 in skimmed revenues.  The owner was indicted on tax and other charges, is currently a fugitive living in Lebanon, his wife went to jail, and the government seized and sold the formerly prosperous restaurants.

Passive Business Owners & Entities With Multiple Locations

Owners are not the only ones who might want to skim, and use a zapper to hide it. A absentee owner as well as owners of multiple locations have two problems if managers or key employees use zappers to hide embezzlement.  In addition to being the victim of the skim, the larcenous employee will tell the IRS and Michigan Treasury that the owner must have done it, and the owner has criminal and civil exposure.  Such owners can protect themselves by unannounced electronic audits to determine if any zappers have been used.  A telltale sign is that servers, per managers, need to be replaced with unusual frequency.  That can well be  an attempt to hide evidence of electronic tampering..

What To Tell Clients

Smaller business clients that have zappers are not going to boast about it to their counsel. You might pass along a proverbial word to the wise to cash business owners.  This new zapper law is out there, it has teeth, and those who ignore it do so at their peril to both personal liberty and treasure.  Also, as noted just above, beware of skimming employees.

© 2012 Varnum LLP

Canadian International Trade Compliance Conference – POSTPONED

THIS EVENT HAS BEEN POSTPONED BY THE ORGANIZER

The National Law Review is pleased to bring you information about the upcoming Canadian International Trade Compliance Conference:

Addressing the Global Trade Compliance Concerns Involving Export Controls, Custom Compliance and Cross Border Trade in CanadaEvent Date: September 12-14, 2012
Location: Toronto, Ontario, Canada
Key conference topics
  • Assess the latest export permit requirements in Canada with Pratt and Whitney Canada
  • Address re-exports of U.S. origin goods from Canada to comply with both Canadian and U.S. export controls with Future Electronics
  • Integrate an effective anti-corruption compliance program as part of a global trade compliance program with Methanex Corporation
  • Analyze supply chain security concerns when dealing with cross border trade with Stanley Black & Decker, Inc.
  • Uncover the updates to the Export Controls List and their impact upon Canadian companies with Research in Motion Limited

Currently, international trade compliance professionals need to stay up to date on the changing regulations within Canada and also abroad. With the changes to the Export Controls List and the ever-complex nature of Canadian-U.S. cross border trade, companies need to be aware of how these changes affect their international trade compliance programs.

Canada’s relationship with the U.S. makes it imperative that the International Trade Compliance community is informed on the impact that U.S. rules and regulations can have on Canadian companies.

Building upon the success of the 2nd Annual International Trade Compliance Conference, the marcusevans Canadian International Trade Compliance conference addresses the Global Trade Compliance Concerns involving export controls, customs compliance and cross border trade in Canada.

By attending this event, industry leaders will be able to overcome any potential challenges in crafting and sustaining a comprehensive trade compliance program.

Attending This Conference Will Enable You To:

1. Dissect the latest updates from the Department of Foreign Affairs and International Trade with Research in Motion Limited
2. Comprehend the U.S. Export Reform Initiative and the impact upon Canadian companies with Public Works and Government Services Canada
3. Develop and understanding of import value and transfer pricing with Ericsson Canada Inc.
4. Focus on NAFTA and other Free Trade Agreements with Plains Midstream Canada

Industry leaders attending this event will benefit from a dynamic presentation format consisting of workshops, panel discussions and case studies. 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.

Audience:

SVPs, VPs, Directors, Superintendents, Supervisors, Engineers, Specialists, Leaders and Managers from the Chemical, Petrochemical, and Refining Industries with responsibilities in:

  • EHS Environmental Health and Safety
  • Safety/Process Safety Management
  • Plant Management/Operations
  • Inspection/Reliability
  • Mechanical/Asset Integrity
  • Manufacturing/Technology
  • Training & Development

Canadian International Trade Compliance Conference – September 12-14, 2012

The National Law Review is pleased to bring you information about the upcoming Canadian International Trade Compliance Conference:

Addressing the Global Trade Compliance Concerns Involving Export Controls, Custom Compliance and Cross Border Trade in CanadaEvent Date: September 12-14, 2012
Location: Toronto, Ontario, Canada
Key conference topics
  • Assess the latest export permit requirements in Canada with Pratt and Whitney Canada
  • Address re-exports of U.S. origin goods from Canada to comply with both Canadian and U.S. export controls with Future Electronics
  • Integrate an effective anti-corruption compliance program as part of a global trade compliance program with Methanex Corporation
  • Analyze supply chain security concerns when dealing with cross border trade with Stanley Black & Decker, Inc.
  • Uncover the updates to the Export Controls List and their impact upon Canadian companies with Research in Motion Limited

Currently, international trade compliance professionals need to stay up to date on the changing regulations within Canada and also abroad. With the changes to the Export Controls List and the ever-complex nature of Canadian-U.S. cross border trade, companies need to be aware of how these changes affect their international trade compliance programs.

Canada’s relationship with the U.S. makes it imperative that the International Trade Compliance community is informed on the impact that U.S. rules and regulations can have on Canadian companies.

Building upon the success of the 2nd Annual International Trade Compliance Conference, the marcusevans Canadian International Trade Compliance conference addresses the Global Trade Compliance Concerns involving export controls, customs compliance and cross border trade in Canada.

By attending this event, industry leaders will be able to overcome any potential challenges in crafting and sustaining a comprehensive trade compliance program.

Attending This Conference Will Enable You To:

1. Dissect the latest updates from the Department of Foreign Affairs and International Trade with Research in Motion Limited
2. Comprehend the U.S. Export Reform Initiative and the impact upon Canadian companies with Public Works and Government Services Canada
3. Develop and understanding of import value and transfer pricing with Ericsson Canada Inc.
4. Focus on NAFTA and other Free Trade Agreements with Plains Midstream Canada

Industry leaders attending this event will benefit from a dynamic presentation format consisting of workshops, panel discussions and case studies. 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.

Audience:

SVPs, VPs, Directors, Superintendents, Supervisors, Engineers, Specialists, Leaders and Managers from the Chemical, Petrochemical, and Refining Industries with responsibilities in:

  • EHS Environmental Health and Safety
  • Safety/Process Safety Management
  • Plant Management/Operations
  • Inspection/Reliability
  • Mechanical/Asset Integrity
  • Manufacturing/Technology
  • Training & Development

Canadian International Trade Compliance Conference – September 12-14, 2012

The National Law Review is pleased to bring you information about the upcoming Canadian International Trade Compliance Conference:

Addressing the Global Trade Compliance Concerns Involving Export Controls, Custom Compliance and Cross Border Trade in CanadaEvent Date: September 12-14, 2012
Location: Toronto, Ontario, Canada
Key conference topics
  • Assess the latest export permit requirements in Canada with Pratt and Whitney Canada
  • Address re-exports of U.S. origin goods from Canada to comply with both Canadian and U.S. export controls with Future Electronics
  • Integrate an effective anti-corruption compliance program as part of a global trade compliance program with Methanex Corporation
  • Analyze supply chain security concerns when dealing with cross border trade with Stanley Black & Decker, Inc.
  • Uncover the updates to the Export Controls List and their impact upon Canadian companies with Research in Motion Limited

Currently, international trade compliance professionals need to stay up to date on the changing regulations within Canada and also abroad. With the changes to the Export Controls List and the ever-complex nature of Canadian-U.S. cross border trade, companies need to be aware of how these changes affect their international trade compliance programs.

Canada’s relationship with the U.S. makes it imperative that the International Trade Compliance community is informed on the impact that U.S. rules and regulations can have on Canadian companies.

Building upon the success of the 2nd Annual International Trade Compliance Conference, the marcusevans Canadian International Trade Compliance conference addresses the Global Trade Compliance Concerns involving export controls, customs compliance and cross border trade in Canada.

By attending this event, industry leaders will be able to overcome any potential challenges in crafting and sustaining a comprehensive trade compliance program.

Attending This Conference Will Enable You To:

1. Dissect the latest updates from the Department of Foreign Affairs and International Trade with Research in Motion Limited
2. Comprehend the U.S. Export Reform Initiative and the impact upon Canadian companies with Public Works and Government Services Canada
3. Develop and understanding of import value and transfer pricing with Ericsson Canada Inc.
4. Focus on NAFTA and other Free Trade Agreements with Plains Midstream Canada

Industry leaders attending this event will benefit from a dynamic presentation format consisting of workshops, panel discussions and case studies. 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.

Audience:

SVPs, VPs, Directors, Superintendents, Supervisors, Engineers, Specialists, Leaders and Managers from the Chemical, Petrochemical, and Refining Industries with responsibilities in:

  • EHS Environmental Health and Safety
  • Safety/Process Safety Management
  • Plant Management/Operations
  • Inspection/Reliability
  • Mechanical/Asset Integrity
  • Manufacturing/Technology
  • Training & Development

Canadian International Trade Compliance Conference – September 12-14, 2012

The National Law Review is pleased to bring you information about the upcoming Canadian International Trade Compliance Conference:

Addressing the Global Trade Compliance Concerns Involving Export Controls, Custom Compliance and Cross Border Trade in CanadaEvent Date: September 12-14, 2012
Location: Toronto, Ontario, Canada
Key conference topics
  • Assess the latest export permit requirements in Canada with Pratt and Whitney Canada
  • Address re-exports of U.S. origin goods from Canada to comply with both Canadian and U.S. export controls with Future Electronics
  • Integrate an effective anti-corruption compliance program as part of a global trade compliance program with Methanex Corporation
  • Analyze supply chain security concerns when dealing with cross border trade with Stanley Black & Decker, Inc.
  • Uncover the updates to the Export Controls List and their impact upon Canadian companies with Research in Motion Limited

Currently, international trade compliance professionals need to stay up to date on the changing regulations within Canada and also abroad. With the changes to the Export Controls List and the ever-complex nature of Canadian-U.S. cross border trade, companies need to be aware of how these changes affect their international trade compliance programs.

Canada’s relationship with the U.S. makes it imperative that the International Trade Compliance community is informed on the impact that U.S. rules and regulations can have on Canadian companies.

Building upon the success of the 2nd Annual International Trade Compliance Conference, the marcusevans Canadian International Trade Compliance conference addresses the Global Trade Compliance Concerns involving export controls, customs compliance and cross border trade in Canada.

By attending this event, industry leaders will be able to overcome any potential challenges in crafting and sustaining a comprehensive trade compliance program.

Attending This Conference Will Enable You To:

1. Dissect the latest updates from the Department of Foreign Affairs and International Trade with Research in Motion Limited
2. Comprehend the U.S. Export Reform Initiative and the impact upon Canadian companies with Public Works and Government Services Canada
3. Develop and understanding of import value and transfer pricing with Ericsson Canada Inc.
4. Focus on NAFTA and other Free Trade Agreements with Plains Midstream Canada

Industry leaders attending this event will benefit from a dynamic presentation format consisting of workshops, panel discussions and case studies. 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.

Audience:

SVPs, VPs, Directors, Superintendents, Supervisors, Engineers, Specialists, Leaders and Managers from the Chemical, Petrochemical, and Refining Industries with responsibilities in:

  • EHS Environmental Health and Safety
  • Safety/Process Safety Management
  • Plant Management/Operations
  • Inspection/Reliability
  • Mechanical/Asset Integrity
  • Manufacturing/Technology
  • Training & Development

Canadian International Trade Compliance Conference – August 21-23, 2012

The National Law Review is pleased to bring you information about the upcoming Canadian International Trade Compliance Conference:

Addressing the Global Trade Compliance Concerns Involving Export Controls, Custom Compliance and Cross Border Trade in Canada

Event Date: 21-23 Aug 2012
Location: Toronto, Ontario – VENUE TO BE CONFIRMED, Canada

Key conference topics
  • Assess the latest export permit requirements in Canada with Pratt and Whitney Canada
  • Address re-exports of U.S. origin goods from Canada to comply with both Canadian and U.S. export controls with Future Electronics
  • Integrate an effective anti-corruption compliance program as part of a global trade compliance program with Methanex Corporation
  • Analyze supply chain security concerns when dealing with cross border trade with Stanley Black & Decker, Inc.
  • Uncover the updates to the Export Controls List and their impact upon Canadian companies with Research in Motion Limited

Currently, international trade compliance professionals need to stay up to date on the changing regulations within Canada and also abroad. With the changes to the Export Controls List and the ever-complex nature of Canadian-U.S. cross border trade, companies need to be aware of how these changes affect their international trade compliance programs.

Canada’s relationship with the U.S. makes it imperative that the International Trade Compliance community is informed on the impact that U.S. rules and regulations can have on Canadian companies.

Building upon the success of the 2nd Annual International Trade Compliance Conference, the marcusevans Canadian International Trade Compliance conference addresses the Global Trade Compliance Concerns involving export controls, customs compliance and cross border trade in Canada.

By attending this event, industry leaders will be able to overcome any potential challenges in crafting and sustaining a comprehensive trade compliance program.

Attending This Conference Will Enable You To:

1. Dissect the latest updates from the Department of Foreign Affairs and International Trade with Research in Motion Limited
2. Comprehend the U.S. Export Reform Initiative and the impact upon Canadian companies with Public Works and Government Services Canada
3. Develop and understanding of import value and transfer pricing with Ericsson Canada Inc.
4. Focus on NAFTA and other Free Trade Agreements with Plains Midstream Canada

Industry leaders attending this event will benefit from a dynamic presentation format consisting of workshops, panel discussions and case studies. 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.

Audience:

SVPs, VPs, Directors, Superintendents, Supervisors, Engineers, Specialists, Leaders and Managers from the Chemical, Petrochemical, and Refining Industries with responsibilities in:

  • EHS Environmental Health and Safety
  • Safety/Process Safety Management
  • Plant Management/Operations
  • Inspection/Reliability
  • Mechanical/Asset Integrity
  • Manufacturing/Technology
  • Training & Development

8th Annual FCPA & Anti-Corruption Compliance Conference

The National Law Review is pleased to bring you information about the upcoming 8th FCPA & Anti-Corruption Compliance Conference:

8th FCPA and Anti-Corruption Compliance Conference
Identifying Changes to the Global Anti-Corruption Compliance Landscape to Maintain and Upgrade Your Existing Compliance Program

Event Date: 12-14 Jun 2012
Location: Washington, DC, USA

Beyond dealing with the FCPA and UK Bribery Act, there are upcoming changes to global Anti-Compliance initiatives being enacted by other major countries. It is imperative that organizations are made aware of these new rules and regulations to be able to meld them all into their organization’s anti-corruption compliance program. Maintaining a robust global compliance program along with performing proper and detailed 3rd party due diligence is of the upmost importance.

Marcus Evans invites you to attend our 8th Annual Anti-Corruption & FCPA Conference. Hear from leading executives within various industries on how to identify new areas of concern when dealing with bribery or working within a company to update an anti-corruption compliance program.

Attending this event will allow you to learn how to mitigate the effects of any possible instances of corruption and bribery both at home and abroad. Discuss solutions and best practices that companies have found when dealing with their anti-corruption compliance programs. This conference will not only review the newest enforcement cases, but also highlight practical solutions to problems dealing with FCPA and global anti-corruption measures.

Attending this conference will allow you to:

-Overcome the issues in dealing and conducting an internal investigation with Dell
-Identify anti-corruption liability concerns for US companies when engaging in Joint Ventures and Mergers and Acquisitions with Crane Co.
-Perform anti-corruption audits to better identify gaps in the compliance program with SojitzCorporation of America
-Promote 
a culture of ethics within an organization to combat non-compliance with Morgan Stanley
-Assess
 the continued challenges in conducting a 3rd party due diligence program with Parker Drilling

The marcus evans 8th Annual Anti-Corruption & FCPA Conference is a highly intensive, content-driven event that includes, workshops, presentations and panel discussions, over three days. This conference aims to bring together heads, VP’s, directors, chief compliance officers, and in-house counsel in order to provide an intimate atmosphere for both delegates and speakers.

This is not a trade show; our 8th Annual Anti-Corruption & FCPA Conference is targeted at a focused group of senior level executives to maintain an intimate atmosphere for the delegates and speakers. Since we are not a vendor driven conference, the higher level focus allows delegates to network with their industry peers.

Canadian International Trade Compliance Conference – August 21-23, 2012

The National Law Review is pleased to bring you information about the upcoming Canadian International Trade Compliance Conference:

Addressing the Global Trade Compliance Concerns Involving Export Controls, Custom Compliance and Cross Border Trade in Canada

Event Date: 21-23 Aug 2012
Location: Toronto, Ontario – VENUE TO BE CONFIRMED, Canada

Key conference topics
  • Assess the latest export permit requirements in Canada with Pratt and Whitney Canada
  • Address re-exports of U.S. origin goods from Canada to comply with both Canadian and U.S. export controls with Future Electronics
  • Integrate an effective anti-corruption compliance program as part of a global trade compliance program with Methanex Corporation
  • Analyze supply chain security concerns when dealing with cross border trade with Stanley Black & Decker, Inc.
  • Uncover the updates to the Export Controls List and their impact upon Canadian companies with Research in Motion Limited

Currently, international trade compliance professionals need to stay up to date on the changing regulations within Canada and also abroad. With the changes to the Export Controls List and the ever-complex nature of Canadian-U.S. cross border trade, companies need to be aware of how these changes affect their international trade compliance programs.

Canada’s relationship with the U.S. makes it imperative that the International Trade Compliance community is informed on the impact that U.S. rules and regulations can have on Canadian companies.

Building upon the success of the 2nd Annual International Trade Compliance Conference, the marcusevans Canadian International Trade Compliance conference addresses the Global Trade Compliance Concerns involving export controls, customs compliance and cross border trade in Canada.

By attending this event, industry leaders will be able to overcome any potential challenges in crafting and sustaining a comprehensive trade compliance program.

Attending This Conference Will Enable You To:

1. Dissect the latest updates from the Department of Foreign Affairs and International Trade with Research in Motion Limited
2. Comprehend the U.S. Export Reform Initiative and the impact upon Canadian companies with Public Works and Government Services Canada
3. Develop and understanding of import value and transfer pricing with Ericsson Canada Inc.
4. Focus on NAFTA and other Free Trade Agreements with Plains Midstream Canada

Industry leaders attending this event will benefit from a dynamic presentation format consisting of workshops, panel discussions and case studies. 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.

Audience:

SVPs, VPs, Directors, Superintendents, Supervisors, Engineers, Specialists, Leaders and Managers from the Chemical, Petrochemical, and Refining Industries with responsibilities in:

  • EHS Environmental Health and Safety
  • Safety/Process Safety Management
  • Plant Management/Operations
  • Inspection/Reliability
  • Mechanical/Asset Integrity
  • Manufacturing/Technology
  • Training & Development

8th Annual FCPA & Anti-Corruption Compliance Conference

The National Law Review is pleased to bring you information about the upcoming 8th FCPA & Anti-Corruption Compliance Conference:

8th FCPA and Anti-Corruption Compliance Conference
Identifying Changes to the Global Anti-Corruption Compliance Landscape to Maintain and Upgrade Your Existing Compliance Program

Event Date: 12-14 Jun 2012
Location: Washington, DC, USA

Beyond dealing with the FCPA and UK Bribery Act, there are upcoming changes to global Anti-Compliance initiatives being enacted by other major countries. It is imperative that organizations are made aware of these new rules and regulations to be able to meld them all into their organization’s anti-corruption compliance program. Maintaining a robust global compliance program along with performing proper and detailed 3rd party due diligence is of the upmost importance.

Marcus Evans invites you to attend our 8th Annual Anti-Corruption & FCPA Conference. Hear from leading executives within various industries on how to identify new areas of concern when dealing with bribery or working within a company to update an anti-corruption compliance program.

Attending this event will allow you to learn how to mitigate the effects of any possible instances of corruption and bribery both at home and abroad. Discuss solutions and best practices that companies have found when dealing with their anti-corruption compliance programs. This conference will not only review the newest enforcement cases, but also highlight practical solutions to problems dealing with FCPA and global anti-corruption measures.

Attending this conference will allow you to:

-Overcome the issues in dealing and conducting an internal investigation with Dell
-Identify anti-corruption liability concerns for US companies when engaging in Joint Ventures and Mergers and Acquisitions with Crane Co.
-Perform anti-corruption audits to better identify gaps in the compliance program with SojitzCorporation of America
-Promote 
a culture of ethics within an organization to combat non-compliance with Morgan Stanley
-Assess
 the continued challenges in conducting a 3rd party due diligence program with Parker Drilling

The marcus evans 8th Annual Anti-Corruption & FCPA Conference is a highly intensive, content-driven event that includes, workshops, presentations and panel discussions, over three days. This conference aims to bring together heads, VP’s, directors, chief compliance officers, and in-house counsel in order to provide an intimate atmosphere for both delegates and speakers.

This is not a trade show; our 8th Annual Anti-Corruption & FCPA Conference is targeted at a focused group of senior level executives to maintain an intimate atmosphere for the delegates and speakers. Since we are not a vendor driven conference, the higher level focus allows delegates to network with their industry peers.