At the annual TRACE Anti-Bribery Forum on April 22, Willkie partner Jeffrey Clark moderated a panel of leaders from the FCPA units of the Department of Justice and the SEC. The panel, entitled FCPA Enforcement in the Biden Administration: Enforcement Priorities, Compliance Expectations and Lessons Learned from Recent Cases, featured Charles Cain, Chief of the Foreign Corrupt Practices Act Unit in the Division of Enforcement of the US Securities and Exchange Commission, and David Last, Principal Assistant Chief of the DOJ’s FCPA unit.
The panel explored recent cases and regulatory guidance, covering, among other topics, what it means for a compliance program to be “adequately resourced,” regulators’ expectations regarding the use of data analytics for compliance purposes, the shift in third-party risk management from a focus on onboarding due diligence to risk management and mitigation throughout the life of the relationship, and authorities’ views on how to manage employees’ use of ephemeral messaging platforms.
Law360 reported on the panel in an article titled, “What Anti-Bribery Authorities Expect From Compliance Teams.” Read the article here (subscription may be required).
For CLEs presented by Clark and other Willkie attorneys on anti-corruption enforcement and compliance, click here and here.