Mike DeBernardis on Compliance Developments from Q1 2022


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

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