For some time now, international cooperation has been the hottest topic of discussion at the American Conference Institute’s International Conference on the Foreign Corrupt Practices Act. This year’s conference was no different, with all of the government speakers, speaking in their personal capacities, suggesting that increasing international cooperation is the most important anti-corruption enforcement trend. However, this increasing cooperation can create headaches for companies who have to work with multiple enforcement authorities investigating in tandem, but not in concert. We analyze what the government speakers said and present the other side of the story from defense counsel around the world. For more on what was said at the conference, see “The DOJ’s FCPA Corporate Enforcement Policy One Year Later
” (Dec. 12, 2018).