At the 33rd ACI International Conference on the Foreign Corrupt Practices Act ("FCPA"), leading prosecutors and regulators from the U.S. and the UK emphasized the importance of international cooperation, self-disclosure, and a heightened focus on individual responsibility.
Cadwalader attorneys summarized key statements and themes that were covered at the conference in a Cadwalader memorandum. Officials from the Department of Justice ("DOJ"), the SEC and the UK Serious Fraud Office (i) described skyrocketing international law enforcement coordination, (ii) announced "sticks" and "carrots" to encourage self-disclosure and cooperation, and (iii) pledged to hold individuals accountable for anti-corruption violations.
The memorandum was authored by Bret Campbell, J. Robert Duncan and James Treanor.
Commentary / Bret Campbell
As expected, the 33rd annual FCPA conference gave key government officials a platform to announce their enforcement priorities and provide guidance on what they believe are emerging trends. The statements made by these officials give FCPA practitioners a road map for how they, or their clients, can meet the high expectations set by both US and UK enforcement agencies.
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