Welcome to the Hughes Hubbard Anti-Corruption and Internal Investigations Practice Group’s Podcast, All Things Investigations. In this podcast, host Tom Fox and members of the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group will highlight some of the key legal issues involved in white-collar and other investigations, both domestically and internationally. In this episode, I visit with Mike DeBernardis, a partner at Hughes Hubbard, about some of the key developments in ethics compliance and FCPA from Q1 2022.
Michael A. DeBernardis is a partner in the firm’s Washington office and a member of the firm’s Anti-Corruption and Internal Investigations and White Collar & Regulatory Defense practice groups. Michael assists clients with internal investigations relating to high-stakes matters including bribery and corruption under the Foreign Corrupt Practices Act, procurement fraud, financial and accounting fraud, money laundering, and other ethics issues and violations of company policy. Michael has represented clients in connection with inquiries by the U.S. Department of Justice, U.S. Securities and Exchange Commission and U.S. Senate Permanent Subcommittee on Investigations, among others.
Key areas we discuss on this podcast are:
- Q1 brought resolutions that were excellent examples for training and increasing understanding about compliance issues.
- One of the more difficult aspects of compliance is scoping investigations.
- View input from your monitor as an opportunity to truly improve your processes, procedures and controls. Having a positive relationship with them is hugely valuable.
- Developing an investigation plan and protocols is an iterative process.
- Changes to the SEC Whistleblower program.
- Anti-corruption implications of the Russian invasion of Ukraine.
Resources
Hughes Hubbard & Reed website
Mike DeBernardis
Coburn and the Attorney/Client Privilege
