ACI's 41st International Conference on the FCPA - DS
Experience the premier conference for the global anti-corruption community, designed exclusively for legal and compliance professionals. Join over 800 cross-industry FCPA practitioners for two days of in-depth discussions and benchmarking on risk management, compliance, investigations, ethics, and enforcement. Benefit from extensive networking opportunities and gain invaluable insights to enhance your expertise and maximize the success of your compliance program.
From understanding the nuances of U.S. and international regulatory expectations, to implementing effective compliance practices, our 2024 event is designed to provide you with the practical tools for navigating the complexities of today’s evolving landscape!
The Flagship Conference for the Global Anti-Corruption Community
Network with Decision-Makers
& COMPLIANCE COUNSEL, GENERAL COUNSEL, CHIEF LEGAL OFFICER
FCPA Compliance Program Essentials: Step-by-Step Guidance on How to Implement the Building Blocks of an Effective Program (Featuring an Interactive Policy Document Exchange)
Cogs Workshop B
2:00 PM–5:30 PM
A Deep Dive into Due Diligence: Your Updated Blueprint on How to Vet FCPA and Corruption Risks Associated with Supply Chains, Third Parties and M&A Transactions
SCHEDULE OF EVENTS
Wednesday, December 4, 2024
MAIN CONFERENCE DAY ONE
7:30 Registration & Breakfast
8:30 Opening Remarks from the Co-Chairs
8:45 FCPA YEAR IN REVIEW
Registration Sponsor:
9:45 The Aftermath of the DOJ’s New Whistleblower Rewards Pilot Program: Assessing the Impact on Internal and External Reporting, and Individual and Corporate Liability Risks
10:45 Networking Break
11:15 Spotlight Interview
11:45 The Great Debate! To Disclose or Not to Disclose?: Leading FCPA Practitioners Debate the Pros and Cons of a Voluntary Self-Disclosure
12:45 Networking Luncheon
12:45 Women in FCPA and Anti-Corruption Luncheon (by invitation only)
Sponsored by:
2:00 International Enforcement Outlook from the SFO, PNF and Swiss AG Office
2:45 BREAKOUT SESSIONS A
Track 1 [Policy to Practice Series] Ephemeral Messaging Tips and Traps: New, Concrete Examples of How to Retrieve, Retain and Review Records to Satisfy DOJ Expectations
Track 2 [Policy to Practice Series] Safe or Not So Safe? Applying DOJ’s M&A Safe Harbor Policy and Other Requirements at the Pre- and Post-Acquisition Stages
Track 3 Latin America in Focus: Adapting Your Compliance Program to the Unique, Heightened Corruption and Related Risks
3:45 Networking Break
4:15 BREAKOUT SESSIONS B
Track 1 [Mock Whistleblower Interview] The Whistle Has Been Blown, Now What? The Finer Points of Handling Internal and External Whistleblower Complaints and Interviews
Track 2 [Policy to Practice Series] Creating Effectiveness with Efficiencies: Rethinking Priorities and Resource Allocation for Entering and Operating in High Risk and Emerging Markets
Track 3 FEPA as a Gateway to More FCPA Prosecutions? Rethinking Your Compliance Protocols, Internal Controls and Disclosure Calculus
5:15 BREAKOUT SESSIONS C
Track 1 [Policy to Practice Series] Critical Considerations for Implementing Compensation Incentives and Clawbacks: Resolving the Latest Real-Life Dilemmas Involving FCPA and International Employment Laws
Track 2 The New Reality of Operating in China and the Future of Your Business: Lessons for Navigating the FCPA Compliance Pain Points Amid Strict Local Laws and Regulations
Track 3 Corporate Governance Roundtable: Inside the New Realities of Reporting to Boards and Audit Committees Using Your Data, Metrics and Risk Story
Birds of a Feather Discussion
A Closer Look at the Strategic Partnership Between Government and the Private Sector
6:15 Networking Cocktail Reception
Thursday, December 5, 2024
MAIN CONFERENCE DAY TWO
8:30 Registration and Breakfast
9:30 Spotlight Address: DOJ
10:00 CONCURRENT SESSIONS
Post-Election Debrief: What’s Behind Us, What’s Ahead, and Predictions for FCPA Risk and Compliance in the Coming Year
11:00 Networking Break
11:30 Interview with DOJ
12:00 CONCURRENT SESSIONS
Behind the Scenes of a DPA, Monitorship and the Aftermath: First-Hand Accounts of the Real-Life Trials and Tribulations— and Compliance Lessons Learned
Registration Sponsor: OR OR
What’s Missing in Your Internal Investigations Roadmap?: The Finer Points of Identifying and Plugging the Gaps Before It’s Too Late
What Would You Do If?... [Live Polling]: Navigating the Latest Dilemmas Involving Gifts, Hospitality & Entertainment
Birds of a Feather Discussion Dissecting Legal Developments from FCPA Trials Against Individuals
1:00 Networking Luncheon Industry Breakout Luncheon Roundtables
2:15 BREAKOUT SESSIONS A
Track 1 What Would You Do If?...Third Party Due Diligence, Monitoring and Risk Management: See How Your Training and Monitoring Know-How Measures Up
Track 2 Managing Cross-Border Investigation Challenges: Traversing New Data Privacy Laws, Blocking Statutes, State Secret Regulations and Local Enforcement Priorities
Track 3 Spotlight on Africa: Navigating the Shifting FCPA Enforcement Landscape
3:15 Networking Break
3:45 BREAKOUT SESSIONS B
Track 1 Managing the Risks of Integrating AI Into Your Compliance Operations: How to Use AI Responsibly, Ethically and in Accordance with Agencies' Expectations
Track 2 The Convergence of FCPA, Export Controls and Economic Sanctions: Adjusting Your Compliance Strategy to Meet the Growing Overlap Between Corporate Crime, Geopolitics and National Security
Track 3 Negotiating a Corporate Resolution: Practitioners Share Insights on the Evolving Landscape of Settlements and Cooperation Credit
4:45 Town Hall: Open Q&A with DOJ, SEC, FBI, and CFTC
5:30 Conference Concludes
CONFERENCE HIGHLIGHTS FOR 2024
New “Policy to Practice” Series
As one of the cornerstones of the 2024 conference, we are excited to introduce our “Policy to Practice” series. We are unveiling new, innovative compliance discussions that are uniquely focused on how companies are operationalizing DOJ guidance, policy announcements and more! New sessions will include more benchmarking opportunities, including:
y Creating Effectiveness with Efficiencies: Rethinking Priorities and Resource Allocation for Entering into Emerging Markets
y Ephemeral Messaging Tips & Traps: New, Concrete Examples of How to Retrieve, Retain and Review Records to Satisfy DOJ Expectations
y Safe or Not So Safe? Applying DOJ’s M&A Safe Harbor Policy at the Pre- and Post-Acquisition Phases
y Critical Considerations for Implementing Compensation Incentives and Clawbacks: Hits and Misses-and Lessons Learned
Mock Whistleblower Interview
Leading FCPA practitioners will engage in a mock whistleblower interview based on a real-world fact pattern! The panel will then dissect the interview, and discuss the finer points of handling internal and external whistleblower complaints. Speakers will also discuss the evolving landscape of corporate and individual liability risks, whistleblower reporting and the prospect of more new rewards programs in other jurisdictions.
The Great Debate: To Disclose or Not to Disclose? A Debate on the Pros and Cons of a Voluntary Self-Disclosure
The gloves are off! During this spirited debate, a panel of former DOJ and SEC officials will argue for/against a voluntary disclosure. The debate will be based on a real-world, hypothetical scenario. Audience members will select the winning team using anonymous polling.
Post-Election Debrief
In the wake of the 2024 presidential election, we will analyze what is behind us and make predictions for the future of FCPA, compliance and geopolitical risk in the coming year — and beyond.
“What Would You Do If…?
In this two-part series, these ever-popular sessions will take you through an anonymous polling exercise of “what would you do” when confronted with complex, sensitive compliance conundrums. Our panelists will reveal the polling results, discuss critical takeaways and offer practical guidance on:
y Navigating the Latest Dilemmas Involving Gifts, Hospitality & Entertainment
y Training and Monitoring Third-Party Business Partners, Distributors, Sub-Distributors and Sub-Dealers
Government Town Hall
Back by popular demand, the closing session of the event will include the acclaimed “Government Town Hall.” Come with your most pressing questions for an open Q&A with the DOJ, SEC, and FBI.
Dedicated Legal, Compliance and International Breakout Sessions
Customize your conference experience by selecting your preferred breakout sessions. Newly revamped for this year, the breakouts will allow you to expand your toolbox of best practices for the year ahead.
Anonymous Audience Polling
With a user-friendly digital polling system, participants will get the chance to respond to panel questions confidentially — an effective way to compare notes with your peers across the globe!
MORE OPPORTUNITIES TO CUSTOMIZE YOUR CONFERENCE EXPERIENCE
New Networking Hubs!
DEC 4 - 10:45 AM, 3:50 PM
New for this year are the designated Networking Hubs where you can gather with members of your specific industry or meet with practitioners from a particular country/jurisdiction. Take advantage of the chance to make connections and plan a meet-up with the people you most want to meet!
Special Industry Group (SIG) Luncheon Breakouts
DEC 5 - 1:00 PM
Expand your industry-specific network and compare notes on managing the FCPA risk factors that are unique to your business. Limited seating is available, so be sure to reserve your spot!
y Technology & Telecom
y Financial Services
y Life Sciences / Healthcare
y Energy & Extractive
“Birds of a Feather” Smaller-Group Roundtables
DEC 4 - 5:20 PM | DEC 5 - 11:30 AM
Our “Birds of a Feather” Roundtables are designed for attendees to engage in focused, smaller-group discussions around topics that are of unique interest to them. Take advantage of the chance to collaborate and compare notes with a group of your peers in a more intimate setting. Roundtable discussions will include:
y Dissecting Legal Developments from FCPA Trials Against Individuals
y A Closer Look at the Fight Against Corruption Through Strategic Partnership Between Government and the Private Sector
Women in FCPA Luncheon (by invitation only)
DEC 4 - 12:45 PM
Our longstanding “Women in FCPA” Luncheon is an invaluable opportunity to forge connections, exchange contact details, and foster relationships that can endure well after the conference.
GLOBAL ANTI-CORRUPTION ADVISORY BOARD
Rebecca Rohr Chief Compliance Officer and Head of Investigations Ericsson
Michael Ortwein Assistant General Counsel & Chief Compliance Officer General Motors
Angela Main Senior Vice President, Global Chief Compliance Officer & Associate General Counsel, Asia Pacific Zimmer Biomet
Una Dean Vice President, Assistant General Counsel, Head of Global Investigations IBM
Kimberly A. Parker Partner WilmerHale
Mark Mendelsohn Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP
Daniel S. Kahn Partner Davis Polk & Wardwell LLP
Kara Brockmeyer Partner Debevoise & Plimpton LLP F. Joseph Warin Partner Gibson, Dunn & Crutcher LLP
Lucinda A. Low Senior Counsel Steptoe & Johnson LLP
Charles E. Duross Partner Morrison & Foerster LLP
GOVERNMENT SPEAKERS INCLUDE:
Nicole Argentieri
Acting Assistant Attorney General
U.S. Department of Justice
Stefan Blättler
General Federal Prosecutor
Office of the Attorney General of Switzerland
David Fuhr
Chief, FCPA Unit, Fraud Section
U.S. Department of Justice
Ian McGinley
Director, Division of Enforcement
U.S. Commodity Futures
Trading Commission
Andrew Gentin
Chief, Corporate Enforcement, Compliance, and Policy Unit, Fraud Section
U.S. Department of Justice
Jean-Francois Bohnert
Chief Public Prosecutor
National Financial Prosecution Office (PNF) (France)
Charles Cain
Chief, FCPA Unit
U.S. Securities and Exchange Commission
Nicole Creola Kelly
Chief, Office of the Whistleblower
U.S. Securities and Exchange Commission
Lauren Kootman
Assistant Chief, Fraud Section, Criminal Division
U.S. Department of Justice
Molly Moeser
Chief, Money Laundering and Asset Recovery Section
U.S. Department of Justice
Sara Chouraqui
Joint Head of Fraud, Bribery and Corruption Serious Fraud Office (UK)
Keith Edelman
Deputy Chief, FCPA Unit
U.S. Department of Justice
Lorinda Laryea
Principal Deputy Chief, Fraud Section
U.S. Department of Justice
Glenn Leon
Chief, Fraud Section
U.S. Department of Justice
Derek Ettinger
Assistant Chief, FCPA Unit, Fraud Section, Criminal Division
U.S. Department of Justice
CONFERENCE CO-CHAIRS
Ana Iacovetta VP, Deputy General Counsel and Chief Ethics & Compliance Officer Cisco
Tracy Price Deputy Chief, FCPA Unit
U.S. Securities & Exchange Commission
Marnee Rand
Trial Attorney - Corporate Enforcement, Compliance, and Policy Unit
Fraud Section
U.S. Department of Justice
Angela Main Senior Vice President, Global Chief Compliance Officer & Associate General Counsel Zimmer Biomet
Shruti Shah
Anti-Corruption Senior Policy Advisor
U.S. Department of State
Eugene Wu
Unit Chief-International Corruption Unit
Federal Bureau of Investigation
Sandra Moser Partner Morgan, Lewis & Bockius LLP
EXPERT SPEAKER FACULTY INCLUDES
Stephanie Accuosti
Global Head of Integrity Investigations
ABB
Jonathan Edward Adams Partner
Baker & McKenzie (Mexico)
Alejandra Montenegro Almonte
Member
Miller & Chevalier
Greg Andres Partner
Davis Polk & Wardwell LLP
Courtney Andrews Partner
White & Case LLP
Carlos Ayres
Founding Partner
Maeda, Ayres & Sarubbi (Brazil)
Elizabeth Avila Vice President, Anti Bribery & Corruption, Americas Deutsche Bank
William Barry Member
Miller & Chevalier
Kevin Bennett
Vice President of Anti-Bribery Compliance
Goldman Sachs
Darryl Bernstein
Partner
White & Case LLP
Lina Braude Chief Compliance Officer
Suntory Global Spirits
Courtney M. Brown Partner
Gibson, Dunn & Crutcher LLP
Patricia Byrne Vice President & Chief Counsel, International Trade Compliance BAE Systems
María González Calvet
Partner Ropes & Gray LLP
Shana Cappell
Global Head of ABAC Compliance & Ethics
Chief Anticorruption and Investigations Counsel PepsiCo, Inc.
Danielle Carter VP, Global Trade & Social Environmental Responsibility Hewlett Packard Enterprise
Gina Castellano Partner
Cadwalader, Wickersham & Taft LLP
Christopher Cestaro Partner WilmerHale
Damara Chambers Partner
Latham & Watkins LLP
Renata Citriniti
Executive Compliance Manager Petrobras
Chris Crowder Head of Ethics & Compliance
Airbus Americas
Bapsy Dastur
General Counsel, HeadCorporate Risk, Compliance & Legal
VFS Global
Una Dean VP, Assistant GC and Head of Global Investigations & Cybersecurity
IBM
Reagan Demas Partner Baker & McKenzie
Ted Diskant Partner McDermott Will & Emery
Andrew Dunbar Chief Compliance Officer Herbalife
Howard Fields Chief Compliance Officer
Mastercard
Paul Frontczak
Associate General Counsel, Group Regulatory, Antitrust, Anti-Corruption and Trade Compliance
Shell
Vivianne (Jabbour)
Gordon-Pullar
Group Chief Compliance Officer
SAP
James Griffin Vice President Risk & Compliance Americas and Global Compliance Operations American Express Global Business Travel
Anthony Grimaldi Partner, Investigations & Forensics PwC
Daniel Grooms Partner Cooley LLP
Steven Gyeszly Chief Compliance Counsel Marathon Oil Company
Robert Hagemann
Chair of the Audit Committee Zimmer Biomet
Susanne Hanchar
Associate Vice President, Global Ethics and Compliance, Anti-Corruption & Investigations Eli Lilly & Company
Hrishikesh Hari Partner Dechert LLP
Michael Culhane Harper Partner K&L Gates
Jannette Hasan
Assistant General Counsel, Corporate Director, Compliance Operations Northrop Grumman
Jennifer Hogan Chief Ethics & Compliance Officer
The Kraft Heinz Co.
Edward Imperatore Partner
Morrison & Foerster LLP
Billy Jacobson Partner
Jacobson Lopez LLC
Robert A. Johnston Partner
Lowenstein Sandler LLP
Daniel Kahn Partner
Davis Polk & Wardwell LLP
David Kelley Partner
O’Melveny & Myers LLP
Benjamin Klein Counsel
Paul, Weiss, Rifkind, Wharton & Garrison LLP
James Koukios Partner
Morrison & Foerster LLP
David A. Last Partner
Cleary Gottlieb
Constantin Lauterwein Partner Hengeler Mueller (Germany)
Angelique Lee
VP, Global Chief Compliance & Ethics Officer Jazz Pharmaceuticals
Leigh Anne Leinen Head of Ethics & Compliance International Woodside Energy
Head of Global Anti-Bribery & Corruption Advisory and Americas ABC Compliance Mitsubishi UFJ Financial Group
Pei Li Wong
Principal - Legal, Monitorships & Investigations BDO USA LLP
Shawn Wright Partner Blank Rome LLP
Adam Yoffie
Executive Director, Head of C&E Investigations & Integrity Line
Bristol Myers Squibb
Jeremy Zucker Partner
Dechert LLP
PRE-CONFERENCE WORKSHOP A December 3, 2024*
9:30 am–1:00 pm (Registration opens at 9:00 am)
FCPA Compliance Program Essentials: Step-by-Step Guidance on How to Implement the Building Blocks of an Effective Program (Featuring an Interactive Policy Document Exchange)
Implementing a robust FCPA compliance program is a critical part of mitigating intensifying risks. Not only is it essential for reducing the risk of violations and government prosecutions, but it also promotes ethical conduct within your company and supply chain, fosters the expansion of your business, and can serve as a competitive edge.
With recent updates to the DOJ’s Corporate Compliance Programs Guidance signaling an increase in agency expectations and oversight, it is more important than ever that companies take the necessary steps to ensure they have an effective compliance program in place.
This comprehensive, interactive workshop will set forth the building blocks of an effective FCPA compliance program and the key hurdles to implementation. In addition to asking your most burning questions, you will benefit from speaker-prepared reference materials and "closed door" discussions.
Topic will include:
• Conducting a risk assessment to analyze your company’s infrastructure and data for compliance
• Mapping out the potential risk contact points that exist throughout the company
• Creating your compliance team: Clearly defining the job descriptions and responsibilities of those devoted to implementing the ABC program at all levels, and across all company functions
• Customizing your FCPA compliance program to your risk profile
• Implementing and maintaining internal controls
Marnee Rand Trial Attorney - Corporate Enforcement, Compliance, and Policy Unit Fraud Section
• Monitoring and auditing compliance program components
• Testing the effectiveness of your program, and reporting on current or anticipated enhancements
• Tailoring training to your organization and employees — and determining how often to re-train
• Incentivizing and disciplining employees who do/don't demonstrate compliance with your policies and protocols
Shawn Wright Partner
Blank Rome LLP
Courtney M. Brown Partner
Gibson, Dunn & Crutcher LLP
PRE-CONFERENCE WORKSHOP B
December 3, 2024*
2:00–5:30 pm (Registration opens at 1:30 pm)
A Deep Dive into Due Diligence: Your Updated Blueprint on How to Vet FCPA and Corruption Risks Associated with Supply Chains, Third Parties and M&A Transactions
Evolving compliance standards, government agency expectations, and emerging technologies require companies and financial institutions to regularly reassess and revamp their approach to risk management when it comes to both third parties/supply chains and M&A transactions.
Attend this workshop and hear from experts who will provide an updated blueprint for evaluating and upgrading your due diligence programs. Walk away with a clear understanding of how to sufficiently vet and monitor third party and transactional risks.
Adam Wolf Head of Global Anti-Bribery & Corruption Advisory and Americas ABC Compliance Mitsubishi UFJ Financial Group
Jannette Hasan
Assistant General Counsel, Corporate Director, Compliance Operations Northrop Grumman
Angelique Lee VP, Global Chief Compliance & Ethics Officer Jazz Pharmaceuticals
Courtney Andrews Partner White & Case LLP
Gavin Proudley
Head of Third Party Risk Proposition Dow Jones
Third-Party / Supply Chain Due Diligence
• Understanding the different approaches and resources needed to adequately vet 1st, 2nd, 3rd, 4th-tier third parties in your business operations and supply chain
• How much due diligence to perform on new third-party relationship vs. ongoing, existing third-party relationships
• What to do with information uncovered during the vetting process: How to evaluate and address red flags
• Incorporating the latest technologies, agency standards, and internal controls and processes into your third-party due diligence program
• Developing a third-party due diligence model that fits your company’s unique risk profile
• The most effective and efficient ways to evaluate and refresh your third-party training programs
• Monitoring third parties to mitigate compliance risks
• Specific techniques that are effective in vetting and monitoring your “on the ground” third-party agents
• Understanding the local customs, practices, government and business environment of the jurisdictions your third parties are operating in
M&A Transaction Due Diligence
• Conducting an initial risk-assessment during the pre-acquisition phase to create a risk profile for the target company
• Carefully considering every aspect of the target company’s business dealings, including their:
» FCPA compliance and control infrastructure
» Corporate governance and ESG
» Government and regulatory touchpoints
• Best practices for:
» High-risk customers
» High-risk jurisdictions where the company does business
» High-risk third-party relationships
» Target company, management and third-party background checks
» Target company compliance program evaluation and testing
» Investigating company interactions with government officials or agencies
• Understanding how to minimize exposure to risk if compliance issues are uncovered during FCPA due diligence: Key considerations for contracting and remediation
• Identifying when remediation is not possible – and addressing those portions of the acquisition by contract
ACI’s Practical Guide to December 3, 2024*
FCPA Data Analytics
Supporting Sponsors
SPOTLIGHT
INTERVIEW:
Matt Galvin Counsel, Compliance & Data Analytics
U.S. Department of Justice
EXPERT SPEAKER FACULTY INCLUDES:
Sidney Bashago Partner Davis Polk & Wardwell LLP
Bryan Judice Vice President of Client Solutions Kona AI
Joe Kaczorowski Senior Vice PresidentRisk, Analytics, Technology and Innovation Mastercard
Michael Koenig Global Chief Ethics and Compliance Officer JBS
Thomas Larsen Head of Integrity Analytics ABB
Andy Miller Chief Analytics Officer Lextegrity
Fiona Moran Partner Davis Polk & Wardwell LLP
Zachary Opperman Director, Operational Risk
Capital One
Tara Palesh
Senior Director, Compliance
Analytics CoE Lead Pfizer
Roberta Paoloni Vice President, Ethics and Compliance Albemarle
Mihnea Rotariu Director, Ethics & Compliance Monitoring, Assessments and Audits
Baxter
Karen Sgoutas
Senior Director, Compliance
Analytics & Systems Stryker
Hyojin Helena Song
Director of Analytics, Compliance & Ethics
Microsoft
Keith Thomas Lead Counsel, Corporate Integrity & Compliance
FedEx Corporation
Omid Uskowi
Senior Director & Associate
General Counsel, Head of Legal Audits, Compliance Analytics & Compliance Investigations Procter & Gamble
Vincent Walden
CEO Kona Al
Aditya S. Yerramilli
Senior ManagerRisk, Compliance & Governance
Google
December 3, 2024*
7:30
8:00 PRE-CONFERENCE PRIMER
Building Your Data Analytics Blueprint: The Fundamentals of Data Collection, Integrity, Governance and Monitoring
Whether you are just getting started, or already off and running with your data analytics program, attendees of this primer will walk away with an understanding and clarification on the critical components of a data analytics program in alignment with DOJ guidance. Topics of discussion will include:
Getting Started
• Making the decision of whether to build your own program in-house or buy an external product/solution
• Developing your risk profile
» Developing an understanding of the current state of affairs of your company: Finding out what risks already exist; and documenting the key company processes, systems, and transactions that need to be monitored
Data
Collection and Integrity
• Accessing and capturing clean, high-value data across multiple data sources and competing systems
Senior Vice President - Risk, Analytics, Technology and Innovation Mastercard
Mihnea Rotariu
Director, Ethics & Compliance Monitoring, Assessments and Audits
Baxter
• Analyzing the data being captured accurately vs. inaccurately; what data is important; what data should be kept and what should be discarded
• Identifying data sources and deciding how to aggregate the data, ensuring good input and output, and deciphering data integrity
• Evaluating the internal and third-party data analytics tools that are available, and deciding which data feeds your organization can leverage
Data
Governance and Monitoring
• Ensuring your data feeds and monitoring tools are coming in and working in real time
• Developing processes for utilizing risk scoring, assessing red flag reports, and determining what warrants internal investigations and further action
• Documenting follow-up and remedial actions within a dashboard platform
• Identifying impediments that limit access to relevant sources of data and understanding how to address them
Joe Kaczorowski
9:20 Co-Chairs’ Opening Remarks
Tara Palesh
Senior
10:30 Launching, Scaling and Adapting a Data Analytics Program: Companies Share What it Took to Implement an Effective Program from Start to Finish
Hear two companies’ first-hand journeys of building a successful data analytics program, including:
• Where the company started, how the program was scaled and how it evolved
• The decisions they made from beginning to end, and the considerations that went into their decision-making
• How they aligned their data analytics program with DOJ guidance
• How they secured the buy-in for resources from company leadership
• Where things could have gone wrong and how they navigated those landmines
Director of Analytics, Compliance & Ethics Microsoft
Roberta Paoloni
Vice President, Ethics and Compliance Albemarle
Matt Galvin
Interviewed By: Fiona Moran Partner Davis Polk & Wardwell LLP
Hyojin Helena Song
11:30 Effectively Using Data Analytics in Risk Detection and Response, and Compliance Program Testing
• Utilizing long-term data analytics to create a direct and accessible channel into your company’s transactional data
• Leveraging data analytics to monitor transactions over a continuous period of time, and flagging areas susceptible to fraud and corruption
• Concrete examples of using metrics and KPIs to evaluate risk detection and compliance red flags
• Which algorithms to use, who should review the data and how to review the data
• Determining which compliance metrics to measure, and comparing them to industry standards and benchmarks for improved predictability
• Assembling qualitative data-gathering tools—such as surveys and questionnaires—to encourage adaptability and accountability
• Leveraging data analytics to evaluate newly acquired entities, including rapid, targeted analyses of any problematic transactions, third parties or conflicts of interest
Bryan Judice
Vice President of Client Solutions
Kona AI
Omid Uskowi
Senior Director & Associate General Counsel, Head of Legal Audits, Compliance Analytics & Compliance Investigations
Procter & Gamble
Karen Sgoutas
Senior Director, Compliance Analytics & Systems
Stryker
In this session, we will closely examine a recent enforcement action in which the DOJ specifically noted the company’s use of data analytics or the incorporation of data analytics into their compliance regimes — ABB. Tune in as ABB’s Head of Integrity Analytics provides a practical look at the case and shared key takeaways, including:
• How the companies’ data analytics programs played a role in their resolution and remediation
• The specific components of their data analytics programs that DOJ was most focused on
• Insights on what can help to earn credit and/or penalty reductions
• Lessons for communicating your data analytics “story” to enforcement authorities
Thomas Larsen
Head of Integrity Analytics
ABB
Interviewed By:
Sidney Bashago
Partner
Davis Polk & Wardwell LLP
Spotlight on AI and ML
• Understanding the latest ways that companies can use AI, ML and predictive analytics to inform, supplement and enhance their own internal compliance program
• Examining specific use cases for AI/ML in monitoring data, predicting behavior and finding corruption
• How to implement AI/ML for use in investigations and third-party transaction testing
Tara Palesh Senior Director, Compliance Analytics CoE Lead Pfizer
• AI User Stories and Breakthroughs: Real life examples of how companies and financial institutions are successfully integrating AI into their businesses, due diligence and compliance operations
Tune in for this panel as speakers share examples of unsuccessful attempts to implement data analytics programs. Hear about critical mistakes that were made in the early, middle and end-stages of the programs’ designs and rollouts — and walk away with a full understanding of what not to do when implementing a program.
4:30 Real-Time Platform Demonstration: Compliance Monitoring with Analytics & AI
See a leading anti-corruption transaction monitoring platform that has been cited by the SEC and has been before the DOJ in multiple FCPA matters. Learn more about how the software provides configurable risk algorithms driving aggregated risk scoring, supports monitoring workflows, visualizes your spend data for risk and incorporates AI.
4:45 Data Analytics Town Hall: More Real-Life Takeaways to Bring Back to Your Desk and Open Q+A
In our concluding session, our expert panelists will share what they have found to be the biggest data analytics program pain points, and how they have gone about tackling and overcoming them. They will provide answers to questions, including:
• How do you ensure the continued effectiveness of the analytics program?
• What are the costs and resources needed for ongoing maintenance, and how can you accurately measure and relay the ROI of using data analytics for compliance purposes?
• How can you best train and support your team to effectively use, leverage and report on data analytics?
• How do you integrate analytics into the broader compliance framework?
Finally, join an invaluable opportunity for open Q&A and ask our expert panelists your most pressing questions. Attendees can also submit questions anonymously in advance via email to Townhall@AmericanConference.com.
The Aftermath of the DOJ’s New Whistleblower Rewards Pilot Program: Assessing the Impact on Internal and External Reporting, and Individual and Corporate Liability Risks
• Analyzing the new risks and opportunities that the DOJ’s Whistleblower Rewards Program creates for companies and individuals
• Understanding the broader significance of the Whistleblower Rewards Program and consequences for company compliance programs
• The interplay of the DOJ program with the SEC program-and the potential interplay of new programs across foreign jurisdictions
• Status update on the DOJ’s inclusion of an “Exhaustion Provision” — requiring that a whistleblower must exhaust all internal reporting channels before reporting to the DOJ
• Takeaways on the whistleblower reward pilot programs recently announced by the U.S. Attorney’s Offices in New York and California: Examining carveouts, exceptions and implications
NEW INDUSTRY & JURISDICTIONAL NETWORKING HUBS!
Take the opportunity over the morning break to join one of our Networking Hubs where you can gather with members of your specific industry or meet with someone from a particular country/region.
Join us for a compelling interview with Ivan Tornos, President and CEO of Zimmer Biomet, and Robert Hagemann, Chair of Zimmer Biomet’s Audit Committee, as they discuss the transformative lessons learned from the company’s two successive FCPA monitorships. Together, they will share insights on navigating regulatory scrutiny, strengthening compliance frameworks, and fostering a culture of transparency. Gain a behind-the-scenes look at how the company addressed its biggest challenges, implemented lasting reforms, and rebuilt stakeholder confidence.
Ivan Tornos
President & CEO
Zimmer Biomet
Robert Hagemann
Chair of the Audit Committee
Zimmer Biomet
Interviewer:
Guy Singer Partner
McDermott Will & Emery
10:45 Networking Break
11:15 Spotlight Interview
11:45 AUDIENCE POLLING
The Great Debate! To Disclose or Not to Disclose?: Leading FCPA Practitioners Debate the Pros and Cons of a Voluntary Self-Disclosure
In this interactive session, a panel of former DOJ officials will present a real-world, hypothetical scenario which sets the stage for a debate around whether a voluntary disclosure of corporate misconduct should be made — or not. Audience members will select the winning team using anonymous electronic polling. Our panelists will address considerations surrounding:
• The DOJ’s Voluntary Self-Disclosure Pilot Program and the criteria for obtaining a DPA or NPA
• The grey areas of the “prompt reporting” requirement
• The likelihood and possible extent of cooperation credit
• Potential for disgorgement
• Remediation considerations
Daniel Kahn Partner
Davis Polk & Wardwell
Christopher Cestaro Partner
Wilmer Cutler Pickering Hale and Dorr LLP
Una Dean
Vice President, Assistant General Counsel, Head of Global Investigations IBM
Laura Perkins Partner
Hughes Hubbard & Reed LLP
David A. Last Partner
Cleary Gottlieb
12:45 Networking Luncheon
Join us for a compelling discussion on the present and future landscape of international anti-corruption enforcement, featuring insights from leading authorities at the UK's Serious Fraud Office (SFO), France's Parquet National Financier (PNF), and Switzerland's Office of the Attorney General. This panel will provide a critical update on the latest developments, priorities and trends shaping anti-corruption efforts across these key jurisdictions.
Sara Chouraqui
Joint Head of Fraud, Bribery and Corruption
Serious Fraud Office (UK)
Jean-Francois Bohnert
Chief Public Prosecutor
National Financial Prosecution Office (PNF) (France)
Stefan Blättler
General Federal Prosecutor
Office of the Attorney
General of Switzerland
Moderator:
Patrick Stokes Partner
Gibson, Dunn & Crutcher LLP
12:45 Women in FCPA Luncheon (by invitation only) Sponsored by:
2:00 International Enforcement Outlook from the SFO, PNF and Switzerland's Office of the Attorney General
Track 1 [Policy to Practice Series]
Ephemeral Messaging Tips and Traps: New, Concrete Examples of How to Retrieve, Retain and Review Records to Satisfy DOJ Expectations
James Griffin Vice President Risk & Compliance Americas and Global Compliance Operations American Express
Global Business Travel
Benjamin Klein Counsel Paul, Weiss, Rifkind, Wharton & Garrison LLP
Dmitry Lukovsky Chief Risk & Compliance Officer
Qualcomm
Along with DOJ’s recent release of new messaging app guidance, it also announced that companies may now face criminal obstruction of justice or spoliation charges if they fail to preserve data from ephemeral messaging platforms.
This panel will delve into specific examples of how companies should be managing their business records and correspondence in accordance with DOJ’s latest expectations. Our panelists will provide practical tips for:
• Conducting risk assessments to understand whether, how, and with whom employees are using off-network apps to conduct business
• Evaluating and updating written policies governing usage, maintenance, and retention
• Overcoming common hurdles to retaining business records and correspondence
• Implementing alternative ways to preserve off-network messages
• Conducting employee training on policy requirements that would be deemed sufficient in the eyes of the DOJ
• Understanding your organization’s technology and how to counteract features such as auto-delete functions that could thwart document preservation
Track
2
[Policy to Practice Series]
Safe or Not So
Safe? Applying
DOJ’s M&A Safe Harbor Policy and Other Requirements at the Pre- and Post-Acquisition Stages
Rachel Samper Chief Compliance Officer
Estee Lauder Companies
Lauren Kootman
Assistant Chief, Corporate
Enforcement, Compliance, and Policy Unit, Fraud Section U.S. Department of Justice
Track 3 Latin America in Focus: Adapting Your Compliance Program to the Unique, Heightened Corruption and Related Risks
Alejandra Montenegro
Almonte
Member
Miller & Chevalier
Adam Siegel
Partner
Freshfields Bruckhaus
K&L Gates
Brian Markley Partner
Cahill Gordon & Reindel LLP
This panel will provide first-hand accounts of how to navigate the grey areas of the new Safe Harbor Policy, as well as other critical due diligence and monitoring considerations for both acquiring and target companies. Topics of discussion will include:
• Strategic considerations for pre-acquisition and integration planning
• Deciphering when self-disclosure may generate additional exposure for your company
» Understanding whether you qualify for the program and the deadlines involved
» DOJ remediation, restitution and disgorgement requirements
» Anticipating how the DOJ will treat information provided by the company if they self-disclose, but fail to achieve safe harbor status
• Examining how the application of the new Safe Harbor Policy has been impacting individuals, board members and target companies
• Assessing how the DOJ might treat target companies if an acquirer walks away from a deal after a disclosure is made
• What criteria have target companies shown thus far in order to receive VSD benefits?
• Best practices for conducting risk-based audits of all acquired or merged businesses as quickly as possible
Deringer
Despite continuous efforts to investigate and prosecute misconduct, corruption remains pervasive throughout Latin America, creating numerous obstacles and heightened risks for companies doing business in the region. This panel will provide insights on navigating the complexities and heightened risks affecting business operations. Topics of discussion will include:
• What recent cases reveal about the evolving landscape of corruption risks in the region
• Understanding the varying local economies, legislation, political landscape and press operations of the different Latin American jurisdictions where you operate
• Tailoring your approach to investigating and addressing actual or suspected corruption
• Engaging with enforcement authorities in multiple jurisdictions
• Avoiding the compliance pitfalls of posed by local laws
• Ensuring your compliance program is designed to mitigate the key risks and distinct challenges of conducting business in the region
• Comparing and contrasting the enforcement risks for local vs. international companies and financial institutions
3:45 Afternoon Break
NEW INDUSTRY & JURISDICTIONAL NETWORKING HUBS!
Take the opportunity to join one of our Networking Hubs where you can gather with members of your specific industry or meet with someone from a particular country/region.
The Finer Points of Handling Internal and External Whistleblower Complaints and Interviews
Rebecca Rohr
Chief Compliance Officer & Head of Investigations
Ericsson
Antonin Levy Partner
Paul Hastings LLP (France)
Karyl Van Tassel
Senior Managing Director | Global Investigations
J.S. Held
Reagan Demas Partner
Baker & McKenzie
During this interactive session, our panelists will act out a mock whistleblower interview. They will then dissect the interview and provide pointers and takeaways for interview best practices, as well as strategies for handling a whistleblower compliant beyond just the interview. They will demonstrate and discuss:
• The nuances of responding to an internal whistleblower report vs. an external report
• Maximizing the use and effectiveness of hotlines, and rooting out meritless reports
• What to do immediately after the whistle has been blown
• Developing a comprehensive and credible internal investigation plan
• Making the decision of whether to hire outside counsel
• Deciding whether to interview the reporter: Weighing the benefits and risks, and understanding when and how to do it
• Whistleblower interview best practices: Tactics for encouraging candid communication and knowing what questions to ask — and not to ask
Track 2 [Policy to Practice Series]
Creating Effectiveness with Efficiencies: Rethinking Priorities and Resource Allocation for Entering and Operating in High Risk and Emerging Markets
Patricia Byrne
Vice President & Chief Counsel
International Trade Compliance
BAE Systems
Bapsy Dastur
General Counsel, Head- Corporate Risk, Compliance & Legal
VFS Global
Shana Cappell
Global Head of ABAC Compliance & Ethics
Chief Anticorruption and Investigations Counsel
PepsiCo, Inc.
Anne Murray Partner
McDermott, Will & Emery
This panel of in-house legal and compliance leaders will provide a behind-the-scenes look at the evolving list of considerations and strategies for minimizing risk and maximizing existing resources when entering and operating in new markets.
• Planning before the launch: The most important risk assessments that companies should be doing before launching head-first into a new market
• Evaluating the resources needed to implement necessary corruption controls in a given market and conducting a cost-benefit analysis of entry
• Defining the role that internal compliance officers play in making the necessary evaluations: How can CCOs and other compliance team members get their voices heard at the table?
• Identifying the unique FCPA challenges, concerns and considerations of the country/region you are entering
Track 3 FEPA as a Gateway to More FCPA Prosecutions? Rethinking Your Risk Profile, Compliance Protocols, Internal Controls and Disclosure Calculus
Derek Ettinger
Assistant Chief, FCPA Unit, Fraud Section, Criminal Division
U.S. Department of Justice
James Koukios
Partner
Morrison & Foerster LLP
Maria Gonzales Calvet
Partner
Ropes & Gray LLP
The new Foreign Extortion Prevention Act (“FEPA”), which makes the solicitation (or “demand side”) of bribes a criminal offense, carries substantial implications for multinationals. This panel will closely examine:
• How FEPA’s enactment could prompt changes to the DOJ’s reporting requirements and enforcement priorities
• How companies should be reassessing their disclosure analysis and anti-corruption risk assessments, policies, and procedures in light of the new law
• Understanding how FEPA, and the protections it offers, can help a company guard against demands for bribes from foreign officials
• Ensuring that employees are sufficiently trained on FEPA’s expanded definition of what constitutes a “foreign official”
• Examining how the new statute could potentially be used to prosecute companies for conspiracy or aiding and abetting bribery
• Preparing for information requests on individual government officials during FEPA investigations
Track 1 [Policy to Practice Series]
Critical Considerations for Implementing Compensation Incentives and Clawbacks: Resolving the Latest Real-Life Dilemmas Involving FCPA and International Employment Laws
Howard R. Fields
Chief Compliance Officer
Mastercard
Jennifer Hogan
Chief Ethics & Compliance Officer
The Kraft Heinz Co.
Amy Schuh Partner
Morgan, Lewis & Bockius LLP
Jennifer Saperstein Partner
Covington & Burling
• Analyzing how the DOJ’s Clawbacks policy is affecting company decision-making around employee compensation structures
• Language in employment contracts to show DOJ they are making good faith efforts to comply with the new policy
• How companies are using predictive analytics and risk assessments to inform clawback, holdback and incentive practices
• Real-world examples of how to implement compensation clawbacks within U.S. and foreign legal parameters
• Navigating the difficulties of instituting clawbacks in tandem with employment laws in foreign jurisdictions
• Identifying ways to incentivize employee conduct in the absence of clawbacks — what is working and not working?
Track 2 The New Reality of Operating in China and the Future of Your Business: Lessons for Navigating the FCPA Compliance Pain Points Amid Local Law and Enforcement Crackdown
Global Head of Integrity Investigations
ABB
Principal - Legal, Monitorships & Investigations
Angela Main
Senior Vice President, Global Chief Compliance Officer & Associate
General Counsel, Asia Pacific
Zimmer Biomet
This panel will dissect the distinct challenges of operating your business amid the current environment in China. Amid geopolitical tensions and conflicting U.S. and local requirements, benefit from best practices for:
• Navigating China’s new data and cyber laws and balancing these requirements with DOJ and SEC expectations for FCPA compliance
• Evolving FCPA compliance programs in response to the latest trends
• Special considerations for onboarding and monitoring third parties in China
• Mitigating the risks associated with interactions involving local government officials and agencies
• Specific considerations and risks for life sciences companies operating in the headwind of China’s sweeping national campaign against healthcare corruption
Track 3 Corporate Governance Roundtable: Inside the New Realities of Reporting to Boards and Audit Committees Using Your Data, Metrics and Risk Story
Victor Miller
Vice President, Deputy
General Counsel
Chief Compliance Officer
Honeywell
Hillary Rosenberg Chief Enterprise
Compliance Officer and Head of Regulatory Relations Valley Bank
Andrew
Chief Compliance Officer Herbalife
Steven
Chief Compliance Counsel Marathon Oil Company
Gain insights from this panel of cross-industry CCOs on what it takes to communicate effectively with your Board of Directors and Audit Committees about your company’s evolving liability risks.
Our panelists will address key topics, including:
• Knowing when and how often you should be meeting with the Board
• Understanding how to resonate with your Board to secure buy-in for important changes and additional compliance resources
• Best practices for telling a compelling “risk story” to your Board using data metrics and analytics
• What level of access to the audit committee does the DOJ expect?
• How compliance teams can work more effectively with outside counsel to help convey company risks to boards and audit committees
• When to engage outside counsel in presentations to Boards and audit committees
Discussion A Closer Look at the Fight Against Corruption Through Strategic Partnership Between Government and the Private Sector
Learn about the U.S. State Department's various initiatives to engage the private sector on anti-corruption, including the OECD's Anti-Corruption Leaders Hub (ACLH) — a multi-stakeholder community comprised of chief compliance officers, senior government officials and civil society leaders.
In this unique segment, attendees will meet members of the ACLH and learn about their latest initiatives to prevent, detect and eliminate corruption.
Assistant General Counsel
& Chief Compliance Officer
General Motors
Erik Veltman
Head of Ethics and Compliance Group
Business Services
Anti-Corruption Senior Policy Advisor Office of the Coordinator on Global Anti-Corruption U.S. Department of State
“Birds of a Feather”
Michael Ortwein
Rolls-Royce
Shruti Shah
Jane Shvets Partner Debevoise & Plimpton LLP
Stephanie Accuosti
Pei Li Wong
BDO USA LLP
Dunbar
Gyeszly
Rachel Maimin Partner Lowenstein Sandler LLP
6:15 Conference Adjourns
Networking Cocktail Reception
MAIN CONFERENCE DAY TWO
December 5, 2024
8:30 Registration and Breakfast
Registration Sponsor:
9:30 Keynote Address: U.S. Department of Justice
Nicole Argentieri
Acting Assistant Attorney General
U.S. Department of Justice It was great to be around the best players in compliance, and integration was the utmost!
10:00 CONCURRENT SESSIONS
Post-Election Debrief: What’s Behind Us, What’s Ahead, and Predictions for the Future of FCPA Risk and Compliance in the Coming Year
Mark Mendelsohn Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
Nicholas Lloyd McQuaid Partner
Latham & Watkins LLP
Gerald Moody Partner
Akin Gump Strauss Hauer & Feld LLP
Sandra Moser Partner
Morgan, Lewis & Bockius LLP
David Kelley Partner
O’Melveny & Myers LLP
Against the backdrop of the recent presidential election, this panel will explore what the future of FCPA risk, compliance and enforcement will look like in the coming year and beyond. Gain insights on the trajectory of FCPA policy, legislation and enforcement activity over the last four years, and what we can anticipate in light of the election result.
11:00 Networking Break
OR
What’s Missing in Your Internal Investigations Roadmap?: The Finer Points of Identifying and Plugging the Gaps Before It’s Too Late
Paige Pratter
Associate General Counsel
- Compliance & Ethics, Head of Business & Regulatory Investigations
Microsoft
Greg Andres Partner
Davis Polk & Wardell LLP
Steven Tyrrell Partner
Brown Rudnick LLP
Billy Jacobson Partner
Jacobson Lopez LLC
Sulaksh Shah
Partner, Investigations & Forensics PwC
While all internal FCPA investigations must be customized to the specific facts, circumstances and issues at hand — there are critical practices and protocols that must be implemented to yield a complete and credible investigative process.
This panel will provide insights on how to identify and remedy gaps in your internal investigation program, and provide best practices for:
• Deciding whether or not an internal investigation should be undertaken in the first place
• Designating who should oversee and conduct the investigation
• When outside counsel should be enlisted in the process
• Tailoring the investigation with privilege protection in mind
• Establishing the scope and procedures of the investigation
• Collecting, preserving and reviewing documents and electronic data
• Conducting witness interviews under high-pressure circumstances
• Weighing considerations around self-reporting and remediation
• Presenting investigative findings and implementing a remediation plan
Take the opportunity to join one of our Networking Hubs where you can gather with members of your specific industry or meet with someone from a particular country/region.
11:30 Spotlight Interview: U.S. Department of Justice, Fraud Section
Glenn Leon Chief, Fraud Section U.S. Department of Justice
12:00 CONCURRENT SESSIONS
Ryan Rohlfsen Partner Ropes & Gray LLP
Behind the Scenes of a DPA, Monitorship and the Aftermath: First-Hand Accounts of the Real-Life Trials and Tribulations—and Compliance Lessons Learned
Andrew Gentin
Chief, Corporate Enforcement, Compliance, and Policy Unit, Fraud Section
U.S. Department of Justice
Lina Braude
Chief Compliance Officer
Suntory Global Spirits
Vivianne (Jabbour) Gordon-Pullar
Group Chief Compliance Officer
SAP
Michael Culhane Harper
Partner
K&L Gates
Kwame Manley
Partner
Paul Hastings LLP
Join in-house compliance executives, leading outside counsel and former monitors as they share the candid, behind-the-scenes aspects of navigating through a monitorship and Deferred Prosecution Agreement (DPA). Key discussion points will cover:
• Strategies for preventing DPA breaches
• Insights into monitor selection criteria and processes
• Effective management of independent compliance monitorships
• Fostering organizational change through cross-departmental collaboration
• Maintaining business operations and addressing stakeholder concerns
• Examples of tangible improvements in policies and training to prevent future misconduct
• Effectively relaying to the DOJ that compliance is integrated into your program
“Birds of a Feather” Discussion Dissecting Legal Developments from FCPA Trials Against Individuals
What Would You Do If?...
Resolving the Latest Dilemmas Involving Gifts, Hospitality & Entertainment
Steph Vogel
Senior Vice President, Deputy Chief Compliance Officer & Assistant General Counsel National Basketball Association (NBA)
Adam Yoffie
Executive Director, Head of C&E Investigations & Integrity Line Bristol Myers Squibb
Robert A. Johnston
Partner
Lowenstein Sandler LLP
Kevin Bennett
Vice President of Anti-Bribery Compliance Goldman Sachs
Gifts, hospitality and entertainment with foreign officials has long been rife with grey areas. As we proceed into 2025, companies continue to reconcile conflicts between FCPA compliance and local customs.
During this session, our panelists will guide attendees through an interactive “what would you do if” exercises to convey current best practices for highly sensitive and tricky gift, hospitality and entertainment dilemmas. OR
• Analyzing recent FCPA trials and verdicts involving individual executives: Highlighting key trends in individual liability, and notable developments in trials, jury instructions, judicial rulings, and more
• Exploring the extent of potential vulnerabilities, and the circumstances under which executives may be held personally liable for compliance failures
• Identifying legal issues and determinations from cases against individuals that can transfer over to cases against companies
• Practical advice on how legal and compliance executives can navigate the risks associated with FCPA enforcement in the face of increasing scrutiny
Keith Edelman Deputy Chief, FCPA Unit
Kimberly Parker Partner Wilmer Cutler Pickering Hale & Dorr LLP
1:00 Networking Luncheon
Industry Breakout Luncheon Roundtables
Expand your industry-specific network and compare notes on managing the FCPA risk factors that are unique to your business. Limited seating is available, so be sure to reserve your spot!
• Technology & Telecom • Financial Services
Track 1 [Hypothetical Scenarios]
What Would You Do If?... Third Party Due Diligence, Monitoring and Risk Management: See How Your Training and Monitoring Know-How Measures Up
Elizabeth Avila
Vice President, Anti-Bribery Corruption Americas Deutsche Bank
Jeremy Zucker Partner Dechert LLP
Gina Castellano Partner
Cadwalader, Wickersham & Taft LLP
Through a series of hypothetical fact patterns and anonymous audience polling, benchmark how your third-party due diligence acumen compares to your peers. Walk away with a clear understanding of how to navigate complex scenarios involving third-party business partners, distributors, sub-distributors and sub-dealers.
• Implementing a “risk-based approach” when instituting compliance protocols for third-party intermediaries and vendors: What are other companies doing?
• Understanding how far companies are expected to go in terms of due diligence measures for sub-distributors and sub-dealers
• How should companies modify their sub-agent interactions in certain high-risk scenarios or jurisdictions?
• How sophisticated should training programs be for sub-agents?
Life Sciences/Healthcare • Energy & Extractive
Track 2 Managing Cross-Border Investigation Challenges: Traversing New Data Privacy Laws, Blocking Statutes, State Secret Regulations and Local Enforcement Priorities
Susanne Hanchar
Associate Vice President Global Ethics and Compliance, Anti-Corruption & Investigations Eli Lilly and Company
Constantin Lauterwein Partner
Hengeler Mueller
Anthony Grimaldi
Partner, Investigations & Forensics PwC
Jonathan Edward Adams Partner
Baker & McKenzie (Mexico)
• Navigating critical legal and cultural differences in how investigations are approached in the U.S vs. other key jurisdictions
• Contrasting the expectations of local authorities and prosecutors
• Applying cross-border blocking statutes and local requirements concerning data privacy, employment law, privilege, corporate law and whistleblower protections
• China and India’s new data privacy and cyber laws, and how they will impact cross-border investigations
• Identifying local challenges and impediments to your investigation early, and formulating an action plan
• Deciding if the internal investigation findings should be reported to the company's board of directors, audit committee, and to U.S. and/or international agencies
Track 3 Spotlight on Africa: Special Considerations for Your Business Amid a Shifting FCPA and Anti-Corruption Risk Landscape
Leigh Anne Leinen
Head of Ethics & Compliance, International Woodside Energy
Darryl Bernstein Partner White & Case LLP
• Contrasting the evolving FCPA enforcement environment in Africa in relation to other high-risk markets
• Tailoring compliance strategies to address the distinct and increased corruption challenges of operating in Africa
• Enhancing internal controls, corporate policies, and procedures
• Formulating a due diligence strategy aligned with varying risk profiles of third parties and throughout the supply chain
• Assessing the implications of recent legislative and enforcement updates
• Managing cross-border investigations involving U.S., African, and global regulatory authorities
• Concrete examples of unique, high stakes scenarios and how to address them on the ground
Track 1 Managing the Risks of Integrating Artificial Intelligence Into Your Compliance Operations: How to Use AI Responsibly, Ethically and in Accordance with Agency Expectations
Danielle Carter VP, Global Trade & Social Environmental Responsibility Hewlett Packard Enterprise
Paras Malik
Managing Director and Partner Boston Consulting Group
Zee Moradi
Chief Data Officer Americas UBS
This panel will provide practical insights and actionable guidance on how to leverage AI in your internal compliance efforts while mitigating associated risks, ensuring ethical practices, and meeting regulatory standards.
• Identifying guardrails that need to be put into place before using AI: The necessary policies, procedures and internal controls
• Establishing frameworks and protocols that prioritize transparency, fairness, and accountability surrounding AI usage
• Understanding potential risks associated with integrating AI into your compliance operations, including data privacy concerns, bias, and algorithmic accountability
• Conducting comprehensive risk assessments and implementing robust mitigation strategies
Track 2 The Convergence of FCPA, Export Controls and Economic Sanctions: Adjusting Your Compliance Strategy to Address the Growing Overlap Between Corporate Crime, Geopolitical Risk and National Security
Paul Frontczak
Associate General Counsel, Group Regulatory, Antitrust, Anti-Corruption and Trade Compliance Shell
Daniel Grooms Partner Cooley LLP
Hrishikesh Hari Partner
Dechert LLP
Damara Chambers Partner
Latham & Watkins LLP
Track 3 Negotiating a Corporate Resolution: Practitioners Share Insights on the Evolving Landscape of Settlements and Cooperation Credit
Anticorruption, export controls, and economic sanctions form a critical nexus in international business compliance. Companies confronting these intersecting regulatory landscapes must adopt an integrated compliance framework that addresses overlapping risks. This panel will delve into critical topics, including:
• Leveraging internal resources to strengthen compliance programs for FCPA, export controls, national security and economic sanctions crosspoints
• Navigating the effects that heightened sanctions enforcement will have on FCPA enforcement
• Managing the increasing overlap between national security and corporate crime, including money laundering to evade sanctions, terrorist financing, and cybercrime
• U.S. cooperation with international partners in recovering assets associated with foreign corruption, sanctions and money laundering
Edward Imperatore Partner Morrison & Foerster LLP
William Barry Member Miller & Chevalier
Carlos Ayres
Founding Partner Maeda, Ayres & Sarubbi (Brazil)
• Examining current trends in corporate settlements: Lessons and takeaway on how to maximize cooperation credit
• Understanding the role of self-disclosure in today’s settlement landscape
• Perspectives on what constitutes "immediate" action
• Examining recent DOJ enforcement activities and statements that outline immediate and extraordinary cooperation
• Determining the appropriate time to engage outside legal counsel
• Examples of successful (and not so successful) negotiations with prosecutors
• Unpacking cases where companies did not self-disclose, but still fully cooperated and remediated in a timely and appropriate manner
4:45 Town Hall with DOJ, SEC, FBI, and CFTC
Lorinda Laryea
Acting Principal Deputy Chief, Fraud Section U.S. Department of Justice
Tracy Price Deputy Chief, FCPA Unit U.S. Securities Exchange Commission
Eugene Wu Unit Chief - International Corruption Unit Federal Bureau of Investigation
Ian McGinley Director of the Division of Enforcement U.S. Commodity Futures Trading Commission
PART I: PANEL DISCUSSION: Participants will gain further enforcement insights from the agencies.
Andrew Levine Partner Debevoise & Plimpton LLP
PART II: OPEN AUDIENCE Q&A: Benefit from an extended opportunity for open Q&A with key enforcement officials — ask your questions in real time or email your questions to: Townhall@AmericanConference.com. Your questions will be asked on an anonymous basis.
5:30 Conference Ends
Gaylord National Resort & Convention Center
With conferences in the United States, Canada, Latin America and Europe, the C5 Group of Companies: American Conference Institute, the Canadian Institute, and C5 Group, provides a diverse portfolio of conferences, events and roundtables devoted to providing business intelligence to senior decision makers responding to challenges around the world.
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Dechert is a global law firm that advises asset managers, financial institutions and corporations on issues critical to managing their business and their capital – from high-stakes litigation to complex transactions and regulatory matters. We answer questions that seem unsolvable, develop deal structures that are new to the market and protect clients' rights in extreme situations. Our nearly 1,000 lawyers across 20 offices globally focus on the financial services, private equity, private credit, real estate, life sciences and technology.
K&L Gates’ White Collar Defense team of former senior DOJ and SEC attorneys leverage the firm’s global footprint to assist clients in the most sophisticated cross-border investigations worldwide.
National law firm Lowenstein Sandler focuses on representing investment funds, life sciences and technology companies while emphasizing entrepreneurial spirit and client service.
Morgan Lewis routinely represents clients who conduct business internationally and face increased challenges addressing anticorruption and other international regulatory risk. Our FCPA/Anticorruption team is made up of a dynamic team of lawyers, including a former chief of the US DOJ Criminal Division Fraud Section, a former US Attorney, more than a dozen former Assistant US Attorneys, and more than 25 SEC alums, including two former SEC regional directors, along with numerous additional federal and state prosecutors and leaders from other government agencies. Our international presence and substantial experience allows us to respond effectively and quickly to FCPA-related issues anywhere they arise. We assist clients with every aspect of FCPA/ UK Bribery Act internal investigations, counseling, and response, including a review of international business activities, analysis of local laws, and FCPA/UK Bribery Act risk assessments. For more information click here or visit www.morganlewis.com
Our team advises clients on all aspects of anticorruption law – designing and improving compliance programs, conducting due diligence on M&A targets and intermediaries, leading internal investigations and negotiating with government enforcement authorities, handling post-resolution compliance responsibilities, and navigating the civil litigation that often accompanies anti-corruption investigations. We offer our clients a deep bench of seasoned professionals, including senior defense lawyers as well as former enforcement attorneys from both the DOJ and SEC. We remain the go-to firm for the largest and most complex global FCPA and anti-corruption investigations and are recognized as the first place most active global law firm advising on FCPA settlements since 2008, and have led more FCPA monitorships than any other firm since 2004.
Our record of success has garnered numerous accolades for our practice: Paul Hastings is ranked Band 1 for Nationwide FCPA according to Chambers, and Law360 named Paul Hastings “White Collar Practice Group of the Year 2021 & 2022.” To learn more, visit https://www.paulhastings.com/
About PwC's Investigations & Forensics
Ever-changing market dynamics, technologies, regulations and unplanned events can obscure the path forward. Through an investigative mindset, intelligence and data analytics, we help our clients build resilient strategies and protect what matters most: reputation and value.
Our Investigations & Forensics specialists who understand the threats and vulnerabilities that exist across industries and territories bring extensive regulatory experience that can help you get the facts fast.
We work with you to institute an FCPA compliance strategy that employs a balanced approach with both proactive measures and defensive tactics, helping you prepare, respond and emerge stronger. To learn more, please visit www.pwc.com/us/forensics
As a truly global law firm, White & Case is uniquely positioned to help clients facing legal and regulatory challenges worldwide. Our cross-border experience and diverse team of local, US and English-qualified lawyers consistently deliver results for our clients. In both established and emerging markets, our lawyers are integral, long-standing members of the community, giving our clients insights into the local business environment alongside our experience in multiple jurisdictions.
We counsel clients on a range of issues with multi-jurisdictional connections, from bribery and money laundering to fraud, sanctions and securities violations. We work with some of the world's most respected and well-established financial institutions and other businesses, as well as start-up visionaries, governments and state-owned entities. We help our clients adopt sound policies and practices, ensure compliance, and protect their competitive advantage.
CONTINUING LEGAL EDUCATION CREDITS
Accreditation will be sought in those jurisdictions requested by the registrants which have continuing education requirements. This course is identified as nontransitional for the purposes of CLE accreditation.
ACI certifies this activity has been approved for CLE credit by the State Bar of California.
ACI certifies this activity has been approved for CLE credit by the New York State Continuing Legal Education Board.
ACI has a dedicated team which processes requests for state approval. Please note that event accreditation varies by state and ACI will make every effort to process your request.
Questions about CLE credits for your state? Visit our online CLE Help Center at www.americanconference.com/accreditation/cle/
Curating Modern, Authoritative, Content for 40 Years
Welcome to ACI Insights, a place where content and thought leaders unite to bring you original and new perspectives on emerging trends and ideas from leaders in the business community.
For four decades, law, compliance, accounting, investigations and advisory firms have chosen ACI and C5 events to connect with key decision-makers and expand their global footprints. With our finger on the pulse of new, emerging trends and developments, we continue to bring you curated, modern content through our exciting new ACI Insights platform.
U.S. Implications of the EU AI Act
The DOJ’s New Pilot Programs: A Bane for Compliance Programs
Whistleblower Programs vs. Compliance: How Can Companies Compete?
U.K. Parliament Giving Whistleblower Protections a Fresh Review
The Foreign Extortion Prevention Act: Much Ado About Nothing?
UPCOMING EVENTS
January
March 12–13, 2025 | Mexico City
ABOUT US
The C5 Group, comprising American Conference Institute, the Canadian Institute and C5 in Europe, is a leading global events and business intelligence company.
For over 40 years, C5 Group has provided the opportunities that bring together business leaders, professionals and international experts from around the world to learn, meet, network and make the contacts that create the opportunities. Our conferences and related products connect the power of people with the power of information, a powerful combination for business growth and success.
