Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, I was joined by HughesHubbardReed partner Mike DeBernardis to discuss the recently announced FCPA enforcement action involving SAP.
Mike DeBernardis is a seasoned expert in the field of FCPA enforcement, with a specific focus on SAP enforcement action and the critical role of compliance programs. Drawing from his extensive knowledge of corruption schemes in various countries and the role of third-party intermediaries in these activities, DeBernardis views the SAP enforcement action as a pivotal case study that underscores the importance of robust compliance programs and proactive remedial actions. He commends SAP for their significant investment in their compliance program and their willingness to alter their business practices, such as severing certain third-party relationships and high-risk conduct. DeBernardis believes these actions reflect a commitment to business integrity and serve as a valuable lesson for companies navigating complex investigations. Join Tom Fox and Mike DeBernardis as they delve deeper into this topic on this episode of All Things Investigations.
Key Highlights:
- SAP’s Corrupt Third-Party Intermediaries and Enforcement Action
- The Power of Cooperation and Remediation
- DOJ’s Emphasis on Cooperation and Technology
Resources:
Hughes Hubbard & Reed website
Mike DeBernardis on LinkedIn
