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

September 21, 2022 11:45am

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