Speaker 04.29.26
04.29
Sanctions Evasion: Identifying Criticial Red Flags Amid Rising Risks in Russia, China and Iran
National Press Club
529 14th St NW
Washington, DC 20045
Service
Contacts
Global anti-corruption compliance is a must for companies operating internationally. While there have been a number of high-profile enforcement cases under the U.S. Foreign Corrupt Practices Act (FCPA), U.S. law is not the only source of risk. Other countries such as the UK and Germany are increasing enforcement efforts targeting their nationals in foreign countries. Moreover, many developing countries are under heightened pressure to devote enforcement resources to domestic bribery.
Companies operating internationally are responsible for complying with what can seem at times to be an overwhelming array of laws and regulations promulgated by the United States, the United Kingdom and other countries.
Several factors have led to a marked increase in global anti-bribery investigations, including a special focus on anti-corruption cases by enforcement officials in both the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC); the adoption of the UK Bribery Act 2010 and the issuance of guidance as to its enforcement by the UK Serious Fraud Office (SFO); the EU’s proposed Harmonized Framework to Combat Corruption; China’s expansion of criminal sanctions for bribery of foreign officials; the Brazilian government’s approval of a sweeping anti-corruption law known as the Brazilian Clean Companies Act; and an increased focus on enforcement of anti-bribery laws by the United Nations, the Organization for Economic Cooperation and Development (OECD) and various regional organizations.
Global collaboration between these regulatory and enforcement agencies has resulted in a significant increase in parallel cross-border, multijurisdictional bribery cases. The rise in anti-corruption investigations highlights the need for continual diligence, particularly when working in developing countries where bribes to public officials may be considered regular business practice.
Companies doing business in high-risk countries need to rely on a legal team that can provide the full range of services related to anti-corruption laws, from general compliance counseling and advice on specific transactions to investigations and representation before government agencies when potential issues are uncovered.
View More
Our Capabilities
Pillsbury works with clients to understand and minimize their risk and exposure to anti-corruption activities around the world. We have assisted clients with compliance programs and defended against enforcement actions, as well as conducted internal investigations in the United States, China, Japan, Latin America and Eastern Europe. These activities involve a wide variety of industry sectors including energy, technology, aerospace, defense, consumer and retail, construction and engineering, telecommunications, and financial services.
Mitigating Risk
Markets are never static. As part of Pillsbury’s front-end risk management services, our international trade lawyers provide a resource for executives and corporate counsel to better understand the practical implications of the anti-corruption laws and all aspects of compliance and enforcement, such as:
Investigating and Resolving Potential Problems
Regardless of a company’s compliance efforts, potential violations of the anti-corruption laws can arise in any area of the globe and need to be addressed with deliberate speed. Companies may learn of potential issues in a variety of ways, including a company whistleblower, due diligence in a merger or acquisition, a financial audit or a government subpoena.
This is where Pillsbury’s extensive experience in internal investigations and white collar defense—working in combination with our international trade group—comes into play. Our anti-corruption team includes a number of former government prosecutors and regulators who have been called upon to:
View More
View More