Creating and deploying best-in-class training is a fundamental aspect of maintaining a successful anti-corruption compliance program, and a robust training program can be a powerful defense if the SEC or DOJ finds a “rogue employee.” But training is inherently limited – training sessions cannot cover the full range of anti-corruption situations an employee may face across geographies, and the sessions themselves are limited by time and cost. How can a company maximize the impact of this important activity? To answer this and related questions, the Anti-Corruption Report is undertaking a series of interviews on FCPA training with experts from different disciplines. This article – the second installment in the series – includes our interview with Billy Jacobson, Senior Vice President, Co-General Counsel and Chief Compliance Officer of Weatherford International, one of the largest oil and natural gas service companies, operating in 100 countries. Prior to his association with Weatherford, Jacobson served as a federal prosecutor for the Fraud Section of the U.S. Department of Justice’s Criminal Division, where he served in various positions, including as Assistant Chief for FCPA Enforcement. He has also been in private practice as a partner at Fulbright & Jaworski L.L.P. In the first installment of this series, the Anti-Corruption Report spoke with Joseph Spinelli, the head of Navigant’s FCPA practice and former Inspector General of New York State. See “FCPA Training That Works: An Interview with Joseph Spinelli, Global Leader of Navigant’s Anti-Bribery & Corruption-FCPA Segment
” (Apr. 3, 2013).