FCPA HOUSTON
January 22–23, 2025
The Westin Houston Medical Center/Museum District Houston, TX
Associate Sponsors Exhibitor
CONFERENCE DAY ONE
Wednesday, January 22, 2025
8:00 Registration and Networking Breakfast
8:45 Opening Remarks from the Co-Chairs
Ryan Hartman Partner Arnold & Porter
Teri Cotton Santos Chief Compliance Officer Phillips 66
9:00 The Future of FCPA Enforcement: 2025 Priorities and Expectations
David Fuhr
Chief, FCPA Unit U.S. Department of Justice
DOJ and SEC will highlight key enforcement takeaways, updates, and priorities for 2025.
11:00 Your “Crystal Ball” on FCPA and Anti-Corruption Compliance: Predictions on New Pain Points, Risks and Best Practices
What are the predictions for the future of FCPA, global compliance and geopolitical risk in the coming year and beyond? Take stock of where we have been, where we are headed and the anticipated impact on legal and compliance.
Leigh Anne Leinen Head of Compliance, International, Ethics & Compliance Woodside Energy
Marianne Ibrahim Chief Compliance Officer ChampionX
10:30 Extended Networking Break
11:00 The DOJ Whistleblower Pilot Program: Where We Are and Where We Are Headed on Reporting and Liability Risks
This session will delve into the complexities and expectations surrounding the new DOJ Whistleblower Program.
• Understanding the broader significance of the Whistleblower Rewards Program and consequences for company compliance programs and whistleblower protections
David A. Last Partner
Cleary Gottlieb Steen & Hamilton LLP
• The interplay of the DOJ and SEC whistleblower programs — as well as the potential interplay with requirements in foreign jurisdictions
• Preparing for the next phase of the DOJ program: Modifications to whistleblower hotlines, reporting systems, HR policies, trainings, internal controls and more
12:00 Taking Stock of AI for Compliance Monitoring: Companies at Various Phases of AI Integration Share Lessons Learned and Unintended Consequences
This panel will provide insights on how to leverage AI in your internal compliance efforts while mitigating associated risks, ensuring ethical practices, and meeting regulatory standards.
Samir Kaushik Partner Jones Day
• Creating robust frameworks and developing protocols that emphasize transparency, fairness, and accountability in AI usage
• Mitigating integration risks and related risks such as data privacy issues, bias, and algorithmic accountability when incorporating AI into compliance operations
• Performing thorough risk assessments, comprehensive evaluations and applying effective mitigation strategies
• Identifying the steps to take when data reveals employees and third parties are not diligently following critical policies
• Discover how technology solutions can streamline the due diligence process, providing real-time insights and improving overall efficiency
1:00 Networking Luncheon
2:00 Fireside Chat
Join us for an exclusive inside look at managing FCPA and sanctions risk.
2:30 CASE STUDY
Navigating Compliance Challenges in Mexico: Key Takeaways to Address Elevated Corruption Risk Factors
This panel will provide insights on navigating the complexities and heightened risks affecting business operations in Mexico amid a new Administration.
• The evolving landscape of corruption risks in Mexico and the region
• Avoiding the compliance pitfalls posed by local laws, customs and more realities on the ground
• Ensuring your compliance program is designed to mitigate the most pressing local risks
• Tailoring your approach to investigating and addressing actual or suspected corruption
Gabriella Neal (Contreras) Global Sanctions & ITC Counsel Halliburton
Benjamin Torres-Barron Partner Baker & McKenzie SC
• Navigating cross-border investigations by the U.S. in coordination with various Latin American authorities, and reaching coordinated resolutions
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 New York State Continuing Legal Education Board.
ACI certifies this activity has been approved for CLE credit by the State Bar of California.
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. For more information on ACI’s CLE process, visit: www.AmericanConference.com/Accreditation/CLE
Jeffrey Taylor Vice President, General Counsel & Secretary ExxonMobil
John C. Richter Partner King & Spalding
3:15 Networking Break
3:30 The Evolving Reality of Third Party Due Diligence, Monitoring and Audits: New Challenges Confronted in High Risk Jurisdictions
• Updating risk assessments of third parties to identify new, emerging risk and compliance issues
• Implementing the newest, advanced due diligence and monitoring techniques
• Overcoming hurdles to continuous monitoring and audits of third-parties
• Addressing pitfalls, such as incomplete information, geographic and cultural differences, resource constraints, and more local, “on the ground” challenges
Andrew Baird Compliance Counsel, West Wood PLC
Doug Cohan Chief Global Compliance Officer The Friedkin Group
This highly anticipated session will delve into the complex issues affecting a company’s disclosure calculus upon discovering an actual or suspected violation. Join our esteemed speakers as they delve into a real-world case study with invaluable takeaways for evaluating the complex factors affecting if, when and how to disclose-and the finer points of engaging with outside counsel, senior management and the Board.
Patrick E. Hays Global Compliance Director Dresser Inc.
Peter V. B. Unger Partner ArentFox Schiff
4:45
DOJ Criminal Division Pilot Program on Self-Disclosure – Overcoming the Challenges to Full Cooperation, and Original and Actionable Information Disclosure
The DOJ’s new self-disclosure pilot program has been designed to increase the effectiveness of voluntary self-disclosures and improve the DOJ’s ability to detect and address corporate criminal conduct.
Building on the previous session, we will discuss:
• Interpreting the “prompt reporting” requirement
• Eligibility criteria for obtaining an NPA or DPA
• Requirements for full cooperation credit: What has and hasn’t been eligible
• Balancing ethical considerations with the desire to avoid prosecution
• The interplay of legal privilege
5:30 Day One Closing Remarks from the Co-Chairs
Networking Cocktail Reception
Joel Cohen Partner White & Case
4:15 Voluntary Disclosure Case Study – Behind the Scenes of Deciding If, When and How to Disclose
CONFERENCE DAY TWO
Thursday,
January 23, 2025
8:00 Registration and Refreshments Available
8:45 Opening Remarks from the Co-Chairs
Ryan Hartman Partner Arnold & Porter
9:00 Fireside Chat
Lance Rollins Supervisory Agent
9:45 The
Teri Cotton Santos Chief Compliance Officer Phillips 66
Newly Discovered Lessons for Ephemeral Messaging: Hits and Misses for Satisfying DOJ Expectations
Amid more DOJ announcements, companies may now face criminal obstruction of justice or spoliation charges if they fail to preserve data from ephemeral messaging platforms. This panel will discuss how companies should be managing their business records and correspondence in accordance with DOJ’s latest expectations.
Our panelists will provide practical tips to:
• Assess risks to determine if, how, and with whom employees are using off-network apps for business purposes
• Regularly evaluate and update written policies to govern the usage, maintenance and retention of business records
• Address common obstacles to retaining business records and correspondence effectively
• Implement alternative ways to preserve off-network communications
James Prince Chief Compliance Officer & Vice President –Legal Sustainability
Baker Hughes
Moderator:
Corinne A. Lammers Partner
Paul Hastings
• Taking a closer look at your organization’s capabilities for meeting DOJ expectations-and knowing which questions to ask your IT team
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10:30 Networking Break
10:45 FEPA’s Role in Boosting FCPA Prosecutions in 2025: Dissecting the Landscape of Enforcement and Risk
The new Foreign Extortion Prevention Act adds a layer of complexity and necessitates a proactive approach to compliance and risk management for companies operating internationally. FEPA makes the solicitation (or “demand side”) of bribes a criminal offense and carries substantial implications for multinationals. This panel will examine:
Jeffery B. Vaden Partner Bracewell LLP
• How has the international landscape been altered and has there been an increase in prosecutions since the enactment of FEPA?
• How FEPA’s enactment could prompt changes to the DOJ’s reporting requirements and enforcement priorities
• Reassessing your disclosure analysis and anti-corruption risk assessments, policies, and procedures in light of the new law
• Understanding how FEPA 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 investigation
11:30 Russia, China, Venezuela, and Iran: How Industry is Rethinking the Growing Convergence of FCPA, Economic Sanctions and Geopolitical Risk
Anticorruption, export controls, and economic sanctions form a critical link 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
• 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
12:30 Networking Luncheon
1:30
Cristina Lunders
Senior Counsel Regulatory Compliance BP
Justin Ross
Vice President, Chief Compliance Officer Sysco
Gavin Proudley
Head of Third Party Risk Proposition Dow Jones
The Latest Verdict on the DOJ’s M&A Safe Harbor Policy: Critical Takeaways for Companies, Individuals and Board Members’ Liability Exposure
• Strategic considerations for pre-acquisition and post-integration planning
• Deciphering when self-disclosure may possibly generate additional exposure for your company
• Understanding whether you qualify under the Safe Harbor policy and the deadlines involved
• How the application of the 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
• Best practices for conducting risk-based audits of all acquired or merged entities
2:15 Making the Toughest Calls on Gifts, Hospitality and Entertainment
Putting DOJ and SEC guidelines for gifts, hospitality, and entertainment remains a big challenge as companies continue to navigate the return to in-person dealings.
This session will discuss current best practices for highly sensitive and tricky gift, hospitality, and entertainment dilemmas using real-world examples.
Ryan Rabalais
Chief Compliance Officer
Seadrill
John Sardar
Deputy Chief Compliance Officer
Sempra Infrastructure
Josh Wallenstein
Founder and Managing Member
The Wallenstein Law Group
3:00 Networking Break
3:15
Focus
on Africa: Navigating the Heightened FCPA and Anti-Corruption Risks and Challenges
• Adapting compliance strategies to tackle Africa’s unique and heightened corruption risks: A breakdown of key regional and energy industry risks
• Strengthening internal controls, corporate policies and procedures
• Developing a due diligence approach tailored to the diverse risk profiles of third parties
• Evaluating the impact of recent legislative and enforcement developments
• Handling cross-border investigations involving U.S., African, and international regulatory bodies
• Real-world examples of high-stakes situations and effective on-the-ground responses
4:00 The
Future
of
Benjamin Haley Partner
Covington & Burling LLP
Irene Onapito
Senior Legal Counsel
Schlumberger Limited
ESG in the Energy Sector: U.S. and State-Level Compliance Hurdles, the Energy Transition-and the FCPA Interplay
• The impact of the U.S. election on SEC enforcement
• Complying with California and other state-level requirements for the “E” and “G”
• The interplay of new EU reporting requirements
• How comprehensive ESG initiatives including third-party due diligence can mitigate potential liabilities and enhance corporate resilience
• Quantifying the financial implications of ESG commitments including strategies for managing risks when ESG goals are not achieved
• How analytics and AI can enable organizations to identify and manage anti-corruption and ESG risks: The lengths and limits
• Key considerations for developing a best-in-class ESG program
4:45 Closing Remarks from the Co-Chairs | End of Conference
Teri Cotton Santos
Chief Compliance Officer
Phillips 66
Mehgan Wichuk
SVP, General Counsel & Chief Compliance Officer
Trillium Flow Technologies
Building VENUE INFORMATION
The Westin Houston Medical Center/Museum District
1709 Dryden Road, Houston, TX, 77030
Phone: (713) 730-2404
ACCOMMODATIONS
American Conference Institute is pleased to offer our delegates a limited number of hotel rooms at a negotiated rate. To take advantage of these rates, please contact the hotel directly and quote "ACI's FCPA Houston".
Please note that the guest room block cut-off date is January 7, 2025. After that date OR when the room block fills, guestroom availability and rate can no longer be guaranteed.
Global Sponsorship Opportunities
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Don’t miss the opportunity to maximize participation or showcase your organization’s services and talent. For more information please contact us at: SponsorInfo@AmericanConference.com
Register and pay to lock in your early rate and be eligible for a full refund until January 9, 2025.
If you are unable to attend for any reason, you will have the following options:
y A full credit note for you, or a colleague to attend another event.
y A full refund. All cancellations and changes must be submitted to CustomerService@AmericanConference.com by January 9, 2025.
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