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Mike DeBernardis on Q1 FCPA Enforcement Highlights


In the Episode, I am joined by Mike DeBernardis, Counsel and Hughes Hubbard. We review the Foreign Corrupt Practices Act enforcement from Q1 and take a look into that veiled land of the future. Some of the highlights include:

  • Key highlights from the Cardinal Health SEC enforcement action.
  • The Airbus international anti-corruption enforcement action is the largest ever. How can a CCO begin to get their arms around it or discern what it might mean for their company?
  • What are Mike’s 3 key takeaways from Airbus?
  • What is the significance of the individual prosecutions in Q1?
  • What are the top questions Mike and the Hughes Hubbard team is receiving from its clients now?
  • While investigations may slow down in Q2, Mike expects an uptick in Q3 & Q4.
  • What are the 5 elements of an ethical culture?
  • There will not be any Free FCPA Pass from the DOJ going forward on enforcement.

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