A Perspective from the FCPA Defense Bar on Brockmeyer and Duross’ “Year In Review”: Interview with Danforth Newcomb, of Shearman & Sterling

Companies operating internationally should pay close attention when government regulators candidly discuss the FCPA.  But how should a company interpret the government’s comments?  How much weight should be given to any individual regulator’s predictions of trends?  At ACI’s recent International Conference on the Foreign Corrupt Practices Act in Washington, D.C., Charles Duross, Deputy Chief of the Fraud Section of the Criminal Division of the DOJ, and Kara Brockmeyer, Chief of the FCPA Unit of the Division of Enforcement of the SEC, provided insight into the specific elements of FCPA enforcement that matter to leading regulators, as detailed in The FCPA Report’s two-part series.  See Part One of Two, Vol. 2, No. 24 (Dec. 4, 2013); Part Two of Two, Vol. 2, No. 25 (Dec. 18, 2012).  In an interview with The FCPA Report following that panel, Danforth Newcomb, a partner at Shearman & Sterling LLP and recognized expert on the FCPA, responded to the most pressing issues raised by Duross and Brockmeyer.  Newcomb’s no-nonsense approach to FCPA compliance and thoughtful dissection of the regulators’ comments enable in-house counsel, compliance officers and others to translate the regulators’ insights directly into actionable policies and procedures.

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