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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    International

Date & Time
  • event Date

    Wednesday, January 15, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00

This CLE course will prepare counsel to companies doing business internationally to establish and carry out auditing and monitoring of foreign agents and intermediaries to manage the risks of Foreign Corrupt Practices Act (FCPA) violations due to third-party misconduct.

Faculty

Chris Miller
Lead Counsel, Compliance and Regional Compliance Officer, North America
General Motors

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John E. Davis
Member, Practice Lead, FCPA and International Anti-Corruption
Miller & Chevalier

Mr. Davis focuses his practice on international regulatory compliance and enforcement issues. He advises on corruption issues around the world, including compliance with the FCPA and related laws and international treaties, and FCPA-related internal investigations and disclosures to the SEC and DOJ. Mr. Davis works with clients to develop and implement compliance programs, conduct due diligence and audit compliance processes.

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Description

Many FCPA compliance risks arise out of the activity of third-party sales agents, distributors, and other intermediaries. Roughly three quarters of FCPA enforcement actions involve actions by third parties for which companies are held responsible. To manage these significant risks, companies should conduct ongoing reviews of the activities of such third parties. Periodic auditing and monitoring of compliance by third-party sales agents, distributors, and other third-party business partners remain as critical components of an effective corporate anti-corruption compliance program.

Listen as our authoritative panel examines the different types of risks created by various types of third-party sales agents and other intermediaries, discusses best practices for FCPA monitoring of the activities of third-party agents, and outlines cost-effective strategies for designing audit and compliance review programs when conducting business around the world.

Outline

  1. FCPA risks created by third-party business partners
    • Legal framework for third-party liability
    • Recent enforcement cases involving third-party activity
    • Unique risks created by different third parties
  2. Planning third-party audit and compliance reviews
    • Scope of work
    • Timing considerations
    • Data collection and analytics
    • Resource allocation
    • Communication protocols
    • Deliverables
  3. Conducting third-party audit and compliance reviews
    • Interviews and data review
    • Managing the process
    • Common challenges
    • "Red flag" findings
    • Post-review action items
    • Remediation options

Benefits

The panel will review these and other key issues:

  • What is the universe of FCPA risks created by different types of third parties?
  • What are the essential steps for effective auditing and monitoring of third parties' FCPA compliance?
  • What cost-effective strategies can businesses utilize to minimize and mitigate FCPA risks posed by third parties?