Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs

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In this podcast, the second in a two-part series, litigation & enforcement partners Mimi Yang and Ryan Rohlfsen continue our analysis of the revised Foreign Corrupt Practices Act (FCPA) Enforcement Policy. Whereas the first part discussed what companies need to know about meeting the U.S. Department of Justice’s standards for an effective compliance and ethics program, this podcast focuses on what it means for companies’ international risk management programs. The podcast covers:

  • Practical considerations for getting full remediation credits
  • The risks involved with self-reporting, including anti-corruption enforcement by foreign authorities and the Securities Enforcement Commission (SEC)
  • The potential reputational consequences of voluntary disclosure

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