Deciphering De-Conflictions: An Interview With WilmerHale’s Kimberly Parker

When “de-confliction” entered the ABAC lexicon a few years ago with its brief mention in the Pilot Program, some practitioners were left wondering what exactly that meant in the context of internal investigations. Government statements on the topic leave many questions unanswered. While it helps to understand the etymology of the word – a military term first used in the 1970s to describe efforts to reduce the risk of collisions on, say, a battlefield between two entities on the same side – it helps even more to have someone who is knowledgeable about the de-confliction process in the FCPA context explain how it all works. The Anti-Corruption Report spoke to Kimberly Parker, a partner at WilmerHale, about how exactly that “stand-down” process works in practice. See our three-part series on the DOJ’s FCPA Corporate Enforcement Policy: “What’s New and What’s Not” (Jan. 10, 2018); “How Important Is the Presumption of Declination?” (Jan. 24, 2018); and “Cooperation and Compliance Expectations” (Feb. 7, 2018). 

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