It used to be that a corporation that wished to resolve claims of anti-corruption violations simply had to negotiate a settlement with U.S. authorities. Until recently, most countries have been content to leave the United States to enforce the FCPA without venturing into the anti-corruption waters themselves. Yet recent multi-jurisdictional developments in anti-corruption law – such as an increase in the enforcement of anti-corruption laws by foreign countries – have complicated companies’ abilities to settle anti-corruption investigations with certainty and predictability. Indeed, foreign investigations following DOJ and SEC settlements have been increasing steadily, including investigations arising out of the Siemens, Panalpina and Bonny Island FCPA settlements. This enforcement trend highlights the need for careful strategic planning, on a multi-jurisdictional level, for handling anti-corruption investigations and settlements. In a guest article, Charles F. Smith and Gary DiBianco, both partners at Skadden, Arps, Slate, Meagher & Flom LLP, and Brittany Parling, a Skadden associate, discuss trends in multi-jurisdictional enforcement of anti-corruption laws and lay out four factors companies should consider when negotiating and evaluating settlements in a multi-jurisdictional context.
Senior Editor Megan Zwiebel recently appeared on a podcast with Perkins Coie White Collar & Investigations partners Gina LaMonica and Caryn Trombino, who discussed the use of AI in compliance programs, including trends in AI-based compliance, steps companies can take to utilize AI in their compliance programs, and how regulators view the use of data and AI in compliance programs. Listen to the podcast here.
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