Anti-Corruption and Trade Regulations: Identifying Common Elements and Streamlining Compliance Programs (Part Two of Two)

The $9 billion dollar fine of French bank BNP Paribas, which pled guilty in late June 2014 to transferring billions of dollars on behalf of Iran, Sudan and Cuba, is a sharp reminder of the government’s continued focus on trade sanctions.  Understanding how and when the FCPA and trade regulations intersect can help companies affected by both laws structure their compliance programs effectively and efficiently.  In a recent webinar hosted by Securities Docket, FCPA and trade regulations experts from KPMG and McGuire Woods came together to explain the details of the Office of Foreign Assets Control (OFAC) regulations and how they compare and contrast to the FCPA.  In part two of our article series, the panelists discuss six common elements of FCPA and trade sanctions enforcement, detail potential anti-corruption and trade regulation synergies and provide four steps for developing a synergistic compliance program.  In part one of this article series, the panelists detailed various OFAC penalties, discussed how OFAC calculates penalties and outlined three issues for companies to consider when negotiating with OFAC.  See also “How Can Anti-Money Laundering Laws Affect an FCPA Compliance Program? An Interview with Former FinCEN Director James H. Freis, Jr. (Part Two of Two)” (Feb. 20, 2013).

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