Anti-Corruption and International Risk Co-leaders Participate in ACI’s 37th International Flagship Conference on the FCPA

Anti-corruption and international risk co-leaders, María González Calvet and Ryan Rohlfsen, participated in ACI’s 37th Flagship International Conference on the Foreign Corrupt Practices Act (“FCPA”) on December 2-3. This year, the annual conference virtually gathered hundreds of anti-corruption professionals across the globe to share their insights and experiences navigating the FCPA and other anti-bribery laws during an ever-changing enforcement landscape. 

On December 2, María and co-panelists Brian Baldrate of Raytheon Technologies, Steven Fagell of Covington & Burling LLP, and Ronald Machen of WilmerHale provided insights on self disclosure decision making. Moderated by Brian Heberling of Steptoe & Johnson, panelists examined practical impact of U.S. disclosures on foreign corruption investigations, initial considerations regarding the benefits and risks of self-disclosure, the U.S. Department of Justice Corporate Enforcement Policy, and drafting disclosures. 

On December 3, Ryan and co-panelists, David Last of the U.S. Department of Justice and Kirk Foster of Huntington Ingalls Industries, participated in an interactive panel examining ephemeral communications quandaries and how the industry is updating policies, procedures and monitoring. Led by Laura Perkins of Hughes, Hubbard & Reed, Ryan, David and Kirk discussed takeaways from the DOJ’s revised policy, addressed high stakes cybersecurity and data privacy dilemmas, the impact of the global pandemic, and implementing internal investigations practices for data localization, collection, and review.