A Closer Look at the Most Recent Compliance Failures, Enforcement and Penalties on Both Sides of the Pond: New Lessons on What Crosses the Line
Chris Cestaro
Former Chief, FCPA Unit, U.S. Department of Justice; Partner
WilmerHale
Michael Ruck
Partner
K&L Gates LLP
- What has triggered suspicion and investigations
- What criteria the DOJ and SFO may now use to select cases
- The weight given to self-disclosures by the agencies
- Update on what crosses the “Adequate Procedures” threshold
- The lengths and limits of the SFO’s cross-border investigative powers
- How recent cases affects multinationals’ day-to-day compliance efforts
- To what extent corporate and individual criminal liability risks are changing