Miller & Chevalier FCPA Teleconference
As reflected in our FCPA Spring Review, the first quarter of 2010 was one of the most active and ground-breaking FCPA seasons in the history of the statute. The Miller & Chevalier FCPA and International Anti-Corruption Practice Group held a teleconference discussing these events and their consequences for anti-corruption compliance. The one-hour session included discussion of the following 2010 developments:
- Highlights of recent enforcement actions, including Daimler, Nexus, and individual prosecutions;
- Joint U.S./U.K. resolutions of Innospec and BAE matters and the significance for companies attempting to resolve multi-national investigations;
- NATCO resolution and its implication for the extortion defense and the Government's focus on immigration payments;
- Issuance of guidance from the U.S. Sentencing Commission and the OECD regarding the design, implementation and oversight of anti-corruption compliance programs;
- U.K. developments, including today's passage of the Bribery Bill; and
- Whistleblower provisions of the proposed Financial Reform Bill.