FCPA Compliance Report – Navigating the Complexities of Self-Disclosure Amidst Political and Legal Uncertainties

In this episode, Tom Fox welcomes back Hughes Hubbard partner Mike DeBernardis to explore the unprecedented criminal indictment of Smartmatic and its implications on self-disclosure policies under the current administration. They discuss the rare occurrence of a company facing criminal charges and how it complicates the risk assessment for potential self-disclosure. The conversation covers the unpredictable nature of DOJ actions, the impact of political influence, and the challenges this situation presents for legal advisors and their clients. They also explore the broader implications for corporate compliance, including the increased complexity in predicting outcomes and the necessity for thorough internal investigations.

Key highlights:

  • Discussion on Smartmatic Indictment
  • Challenges in Self-Disclosure
  • Political Influence and Risks
  • Client Conversations and Risk Assessment

Resources: 

Hughes Hubbard & Reed

Mike DeBernardis on LinkedIn

Tom Fox

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