In this episode of the FCPA Compliance Report I welcome back Mike DeBernardis, a partner at Hughes Hubbard, about some of the key developments in ethics compliance and FCPA from Q1 2022. Highlights include:
- Q1 brought resolutions that were excellent examples for training and increasing understanding of 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
