Brockmeyer and Stokes Offer Four Benefits of Cooperation and Four Ways Companies Can Go Wrong in Their Internal Investigations

As government enforcers become increasingly sophisticated about business practices and bribery – and adjust their strategies accordingly – companies can be left befuddled as to what is expected from them.  In our previous issue, the Anti-Corruption Report analyzed the DOJ and SEC’s changing approaches in detail based on the “Year in Review” panel at this year’s ACI FCPA conference.  During that panel Kara Brockmeyer, Chief of the FCPA Unit of the Division of Enforcement of the SEC, and Patrick Stokes, Deputy Chief of the Fraud Section of the Criminal Division of the DOJ, also clarified their expectations for companies and their compliance programs.  The Anti-Corruption Report spoke to several anti-corruption defense experts to find out whether these expectations are reasonable and how companies can best meet them.  For coverage of last year’s panel, see “Top FCPA Enforcers Tout Voluntary Disclosure and Warn About International Cooperation; The Defense Bar Responds” (Dec. 3, 2014); and “Top FCPA Officials Talk Compliance Tips and the Defense Bar Weighs In” (Dec. 17, 2014).

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