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Practical and entertaining education for
attorneys, accountants, business owners
and executives, and investors.
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DISCLAIMER
The material in this webinar is for informational purposes only. It should not be
considered legal, financial or other professional advice. You should consult with an
attorney or other appropriate professional to determine what may be best for your
individual needs. While Financial Poise™ takes reasonable steps to ensure the information
it publishes is accurate, Financial Poise™ makes no guaranty in this regard.
About this PowerPoint: if you are looking at this PowerPoint without the benefit of
listening to the conversation that surrounded it then you are doing yourself a disservice.
This PowerPoint was prepared in contemplation of being viewed in conjunction with
listening to a one hour webinar on the topic
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MEET THE FACULTY
Moderator:
Rafael X. Zahralddin – Elliott Greenleaf
Panelists:
Guillermo Christensen – Ice Miller LLP
Corey Lee – Hunton Andrews Kurth
Jonathan Stemerman – Elliott Greenleaf
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ABOUT THIS WEBINAR: Foreign
Corrupt Practices Act Compliance
The Foreign Corrupt Practices Act (“FCPA”) prohibits a U.S. company or person from bribing
foreign government officials to obtain a business advantage. Along with this seemingly simple
restriction comes accounting and record keeping requirements with which companies must
comply. The FCPA requires the implementation of a compliance program which addresses
FCPA concerns and establishes an FCPA corporate policy. This webinar covers the basics of the
FCPA, including an introduction to the regulators, both the SEC and DOJ, and recent
communications to the public regarding the FCPA from these regulatory bodies. The standards
for a compliance program review is analyzed, including what makes a program current and
effective as well as how often the program requires review. The role of a compliance
coordinator is discussed, as is record keeping, training, and retaliation. Finally, meals and
entertainment, gifts, travel, charitable contributions, and hiring will all be discussed with
reference to recent government actions and legal decisions.
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ABOUT THIS SERIES:
Corporate & Regulatory Compliance
Boot Camp
This webinar series covers corporate and regulatory compliance as it relates to procurement
and government contracting, the Foreign Corrupt Practices Act, data privacy and social
media. The various episodes examine these topics from a company’s perspective, delving into
compliance issues that pertain to specific company practices across industries and borders
and impact companies of all sizes and types. Each episode is delivered in Plain English
understandable to business owners and executives without much background in these areas.
Yet, each episode is proven to be valuable to seasoned professionals.
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EPISODES IN THIS SERIES
6/6/19 Episode #1:
Procurement & Government Contracting Compliance
7/11/19 Episode #2:
Foreign Corrupt Practices Act Compliance
8/8/19 Episode #3:
Data Privacy Compliance
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Dates shown are premiere dates.
All webinars will be available
On Demand approximately 4 weeks
after they premiere.
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Episode #2:
Compliance with U.S. Global Trade Laws:
Foreign Corrupt Practices Act
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FOREIGN CORRUPT PRACTICES ACT
• Telia – The Sweden-based telecommunications provider agreed to pay $965 million in a global
settlement to resolve violations of the FCPA to win business in Uzbekistan. (9/21/17)
• Halliburton – The company agreed to pay $29.2 million and a former vice president agreed to
pay a $75,000 penalty to settle charges related to payments made to a local company in Angola
in the course of winning lucrative oilfield services contracts. (7/27/17)
• Michael L. Cohen and Vanja Baros – The former Och-Ziff executives were charged with being the
driving forces behind a far-reaching bribery scheme that paid tens of millions of dollars in bribes
to high-level government officials in Africa. (1/26/17) NOTE: Och-Ziff and other
executives settled charges in 2016.
• Orthofix International – The Texas-based medical device company agreed to pay more than $6
million to settle charges that its subsidiary in Brazil used high discounts and improper payments
to induce doctors under government employment to use Orthofix products. (1/18/17)
Source- https://www.sec.gov/spotlight/fcpa/fcpa-cases.shtml
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FOREIGN CORRUPT PRACTICES ACT (CON’T)
• SQM - Chilean-based chemical and mining company Sociedad Quimica y Minera de Chile S.A.
agreed to pay more than $30 million to resolve parallel civil and criminal cases finding that it
violated the FCPA by making improper payments to Chilean political figures and others.
(1/13/17)
• Biomet - The Warsaw, Ind.-based medical device manufacturer agreed to pay more than $30
million to resolve SEC and Justice Department investigations into the company's anti-bribery
violations in Brazil and Mexico. (1/12/17)
• Cadbury Limited/Mondelez International - The global snacking business agreed to pay a $13
million penalty for FCPA violations occurring after Mondelez (then Kraft Foods Inc.) acquired
Cadbury and its subsidiaries, including one in India that proceeded to make illicit payments to
obtain government licenses and approvals for a chocolate factory in Baddi. (1/6/17)
Source- https://www.sec.gov/spotlight/fcpa/fcpa-cases.shtml
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FOREIGN CORRUPT PRACTICES ACT
(CON’T)
• U.S. businesses with foreign contacts
• Foreign subsidiaries of U.S. businesses
• Select foreign companies and individuals
• Catch-All - “any person” who commits bribery on a U.S. Territory
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ISSUERS
• Issuers are defined as a publicly traded company with 500 or more shareholders
and more than $1 million in total assets
• Domestic Issuers are responsible for the acts of officers, employees, agents, and
other representatives
• Domestic Issuers are responsible for subsidiaries, even if they don’t have a 50%
ownership interest
• FCPA accounting and reporting requirements for Issuers
• Issuers have enhanced penalties for non-compliance
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DOMESTIC CONCERNS
• Any business organized in the United States, U.S. citizen or resident
• Domestic Issuers are responsible for the acts of officers, employees, agents, and
other representatives
• Domestic Issuers are responsible for subsidiaries, even if they don’t have a 50%
ownership interest
• Domestic Concerns are subject to anti-bribery rules, but not reporting
requirements
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ACCOUNTING AND RECORD
KEEPING FOR ISSUERS
• Issuers must keep detailed records
• FCPA accounting provisions facilitate exposing illegal payments
• Records
1. “Accurately and Fairly” reflect all of the issuer’s transactions and assets
2. “Reasonable Detail”
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BRIBERY OF FOREIGN OFFICIALS
• Issuers, Domestic Concerns, and their agents or representatives are subject to
the FCPA’s anti-bribery rules
✓ U.S. nationals and businesses (including foreign subsidiaries) can not engage
in bribery of foreign officials
✓ Foreign nationals and businesses in the U.S. or it's territories can not engage
in bribery of foreign officials
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BUSINESS SCENARIOS WITH ELEVATED RISK
• Permitting / licensing
E.g., payment to expedite a federal/regional/municipal/local permit to operate a certain type
of facility; payment to obtain environmental or construction permit without conforming to all
requirements
• Government contracts
E.g., payment to win or extend a government contract or to gain an advantage in negotiations
with a government customer
• Public procurement
E.g., payment to gain an advantage in a tender (disqualify another bidder, influence tender
specifications, obtain confidential tender information, etc.)
• Customs
E.g., payment to avoid required registration; payment to avoid or lower duties
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BRIBERY – FOREIGN OFFICIALS
• Foreign Officials – intentionally broad definition
1. Not limited to public officials in foreign governments
2. Political parties, their officials, and all candidates for public office
3. Employees of state-owned or state-controlled corporations (e.g. universities, hospitals,
utilities)
4. Officers and employees of public international organizations (organizations whose
employees are treated the same as diplomats; e.g. World Bank, EBRD)
5. Intermediaries officially acting on behalf of a foreign official
6. Relatives or dependents of a foreign official
• Significant risk in many countries (e.g. China): an employee of a seemingly private
enterprise may be an “official” under the FCPA
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BRIBERY – IMPROPER PAYMENTS
• “Payment” – not just money but anything of value
• Includes promises, offers, and the authority to make payments in addition to
payments that are completed
• Foreign official does not have to receive the benefit of the payment
• Can’t use a surrogate/intermediary – an indirect payment is a payment
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LEVEL OF KNOWLEDGE REQUIRED
FOR PAYMENTS
• Payor doesn’t need to know that a payment is or may be improper
• “Conscious disregard of suspicious circumstances”
• “Deliberate ignorance” of an illegal payment
• “Corruptly” = intent “to induce the recipient to misuse his official or to influence
someone else to do so.”
• Voluntarily and with “bad purpose” in order to “obtain or retain business”
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ALLOWABLE PAYMENTS
• Foreign officials requesting or suggesting the bribe does not sanitize the
transaction or reduce liability
• Extortion payments are not subject to liability under the FCPA
✓ Narrow exception, does not include economic coercion
• Payment made with conscious disregard of circumstances suggesting that a
foreign official will benefit from it likely violates the FCPA
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ALLOWABLE PAYMENTS (CON’T)
• Must be carefully exercised as there are narrow exceptions
1. “Expedite or to secure the performance of a routine governmental action” -
“Grease payments” allowed for expediting non-discretionary actions by
minor officials
2. Payments explicitly allowed under the host country’s written laws
3. Reasonable and bona fide expenditures that are directly related to
promotion or demonstration of products or the performance of a
government contract are allowed (payments designed to cover travel and
lodging incurred by government officials as part of normal business
operations
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KEY RISK AREA - THIRD PARTIES
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• Indirect payments are improper: e.g., through consultants, sales agents, customs agents,
distributors, contractors, lawyers, etc.
• Third parties play a role in the majority of all FCPA enforcement actions
• Ignorance is not bliss – companies must act upon third-party “red flags.” E.g.:
• Red flags are not a violation but warrant further inquiry, particularly depending on the third
party’s role and the potential for improper activity
1. Shell company / inadequate staff
2. Little experience or insufficient
qualifications in its line of work
3. Negative or questionable reputation in
its market
4. Uses bank accounts in off-shore
havens or unrelated countries
5. Bank accounts in off-shore havens or
unrelated countries
6. Vague language in invoices to describe its
services
7. An official requested the use of this third
party
8. Is owned by or related to an official
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KEY RISK AREA – IMPROPER PAYMENT TYPES
• Travel and Hospitality
E.g., airfare (esp. first-class), hotel stays, expenses, and/or high per-diems, particularly in
popular destinations or locations without a business nexus, or for family members even
where a business purpose exists
• Gifts and Entertainment
E.g., extravagant gift-giving (luxury watches, shopping sprees, computer equipment, etc.),
expensive wine-and-dine, or multiple gifts of smaller value
• Charitable/political contributions
E.g., donation to a charity associated with a government official’s relative or to a political
party, seeking for the official to exercise any authority or influence
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ENFORCEMENT
• SEC
✓ Civil suits and enforcement of FCPA’s accounting requirements
• DEPARTMENT OF JUSTICE
✓ Criminal prosecution
• Agencies work together through referrals and will work together on some cases
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DISGORGEMENT (SEC ACT OF 1934) - TELIA
• Telia Company AB's $965.6 million settlement September 2017 included disgorgement to
the SEC of $457 million, the biggest disgorgement ever ordered in an FCPA enforcement
action.
• Telia won't actually pay the SEC $457 million in disgorgement.
• About $40 million of the disgorgement will be satisfied by a forfeiture payment to the DOJ.
• Up to $208.5 million will be offset for any confiscation or forfeiture payment Telia makes to
Swedish or Dutch prosecutors.
• So from the total disgorgement of $457 million ordered by the SEC, subtract $40 million for
the DOJ forfeiture, and $208.5 million for the Dutch and Swedish payments.
• That leaves disgorgement actually payable to the SEC of $208.5 million, or half of the
ordered $457 million.
Source http://www.fcpablog.com/blog/2017/9/25/telia-also-tops-our-new-top-ten-
disgorgements-list.html
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PRISON SENTENCES AND YATES MEMO
• Top Five Longest FCPA Related Prison Sentences
1. Joel Esquenazi: 180 months (2011)
2. William Jefferson: 156 months (2009)
3. Charles Paul Edward Jumet: 87 months (2010)
4. Carlos Rodriguez: 84 months (2011)
5. Douglas Murphy: 63 months (2005)
Source- http://www.fcpablog.com/blog/2017/9/25/telia-also-tops-our-new-top-
ten-disgorgements-list.html
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PRISON SENTENCES AND YATES MEMO
(CON’T)
• Companies will have to turn over information on involved individuals in order to get
cooperation credit
• All investigations will start with a focus on individuals in a company
• Criminal and civil attorneys will work in lockstep on corporate cases, sharing information
freely
• Senior DOJ attorneys approve protection
• Individual actions have to be resolved or have a plan before corporate actions can be
resolved
• Civil actions will be pursued against culpable individuals, even if they can’t pay a substantial
fine
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YATES MEMO LIABILITY
• Corporations are responsible for the criminal acts of their employees
1. Acting in apparent or actual scope of employment and
2. Intends in part to benefit the company
3. Even if the actions violate Coporate policy or express corporate order
4. If the employee is guilty the company is guilty
• Corporation’s timely and voluntary disclosure is helpful
• Corporation’s remedial actions are helpful
• Corporate compliance, existence and effectiveness, also are evaluated
• Upjohn – Corporate Miranda
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DODD-FRANK ACT – PRIVATE REFERRALS
AND WHISTLEBLOWER PROTECTIONS
• Whistleblowers, including foreign nationals, can apply for monetary rewards based on
reporting bribery prohibited under the FCPA.
• The Dodd-Frank Wall Street Reform and Consumer Protection Act mandates that the
U.S. Securities Exchange Commission (SEC) pay whistleblowers monetary rewards (Ten
to thirty percent of the amount recovered) if they provide the U.S. government with
information that leads to the successful enforcement of the FCPA.
• The Act is applicable even if bribes are paid in a foreign country and the whistleblower is
a foreign national.
• Anonymity is protected and there are anti-retaliation provisions that provide protection
for employees who work in the United States
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WILDLIFE CRIMES (CASE STUDY ON
CONCURRENT LIABILITY WITH OTHER
FEDERAL AND INTERNATIONAL COMPLIANCE)
• Wildlife trafficking and related wildlife crimes often involve FCPA violations.
• Example, if a publicly traded cargo company bribed an official at a Liberian port
so that the company could load ivory (or illegal timber, etc.) onto the ship
without the official interfering, this would be a violation of the FCPA.
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WILDLIFE CRIMES (CASE STUDY ON CONCURRENT
LIABILITY WITH OTHER FEDERAL AND
INTERNATIONAL COMPLIANCE) (CON’T)
• Whistleblowers worldwide can qualify for monetary rewards when reporting wildlife
trafficking, illegal logging and illegal fishing.
1. The Lacey Act and the Endangered Species Act, direct the Fish and Wildlife
Service, the National Marine Fisheries Service and the Departments of Interior,
Commerce, Treasury and Agriculture to pay monetary rewards to persons who
disclose original information concerning wildlife crimes that results in a successful
enforcement action.
2. Whistleblowers may also qualify for rewards under the Foreign Corrupt Practices
Act and the Act to Prevent Pollution from Ships/ Marpol Protocol.
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PENALTIES
• PUBLICLY TRADED COMPANIES
1. Barred from doing business with government agencies or contractors
2. Export licenses suspended or debarred from the Commodity Futures Trading
Commission
3. FCPA can trigger other enforcement actions from a variety of agencies
• Willful violations can result in $25 million fines for accounting violations and $2 million
for a violation of anti-bribery provisions
• Civil penalties of up to $10,000 per violation
• Defense costs are substantial
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SEC FCPA OPINION PROCEDURE
• Issuers and Domestic Concerns can obtain an opinion of the Attorney General as to whether specific,
prospective, not hypothetical, conduct on firm’s with the Department’s present enforcement policy
regarding the anti-bribery provisions of the FCPA. Response is required by 30 days of the receipt of
complete information in a request.
1. Must be submitted in writing
2. Actual and not hypothetical requirement does not require an executed contract
3. Only applies to the applicant parties
4. Requires
a) Disclosure of all relevant and material information
b) Authorized by the CEO and signed by a senior officer that has the operational responsibility
for the conduct under review
c) The Justice Department can require the CEO of the applicant and any subsidiaries to also
attest to the truth of the submission
• Does not excuse the applicant from the accounting requirements.
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PENALTIES
• Accounting
✓ Willful violations by individuals can be up to $5 million and twenty years in prison
for each violation
• Anti-bribery
✓ Willful violations by individuals can be up to $100,000 and five years in prison for
each violation
• Civil penalties can be up to $10,000 per violation
• Corporations can not indemnify or pay any fines levied against their employees or
agents under the FCPA
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FCPA COMPLIANCE
• Any payments to foreign officials must be scrutinized or avoided
• Due diligence on foreign partners and surrogates is crucial (including continuous review
of books and records)
• Contracts must include FCPA compliance provisions, including that a violation is a
material breach
• Avoid cash payments (harder to track and reduce the ability to make transactions
transparent) and keep fees reasonable to avoid making transfers suspect
• Codes of conduct, education, reporting protocols, and careful screening of all employees,
especially those working abroad
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ABOUT THE FACULTY
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Rafael X. Zahralddin – RXZA@elliottgreenleaf.com
Rafael X. Zahralddin-Aravena is a Shareholder, Director, and Chair of his firm’s Commercial
Bankruptcy and Restructuring Practice. He founded the Elliott Greenleaf Delaware office in 2007,
which specializes in business law, as its first Managing Shareholder. He works as a litigator and
advises businesses on issues of compliance, corporate formation, corporate governance, insolvency,
distressed mergers and acquisition, commercial transactions, cyber law, and international and cross
border issues. He is a National Association of Corporate Directors Governance Fellow.
He has been lead counsel in several significant matters including serving as special litigation
counsel in Washington Mutual, the largest bank insolvency in U.S. history. In the Nortel
bankruptcies he successfully secured a settlement of more than $50 million for the permanently
disabled former employees of the company. The firm and Mr. Zahralddin were named among the
firms that received multiple awards in 2014, culminating in the Large Company Transaction of the
Year Award from the Turnaround Management Association for their work in the AgFeed USA, Inc.
bankruptcy, which involved the sale of the U.S. and China assets of a publicly traded company.
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Guillermo S. Christensen – guillermo.christensen@icemiller.com
Guillermo Christensen is a partner in the DC and New York offices of Ice Miller LLP and practices in the White
Collar and Data Security and Privacy groups. Mr. Christensen is a former CIA intelligence officer and a diplomat
with the Department of State with multiple international tours and domestic assignments including with the
FBI. Guillermo has conducted numerous sensitive internal investigations on FCPA, OFAC and export control
matters for clients in high-risk jurisdictions — he was worked investigations in the Middle East, including in
Kurdistan/Iraq, Saudi Arabia, and Egypt; in Latin America (Mexico, Venezuela, Colombia, Ecuador, Argentina
among many others), Asia and Africa. He also conducts in-depth diligence of third parties for clients, including
several in Myanmar, Brunei, Malaysia, China, Chad, Angola, Nigeria, among others. His clients span the energy,
transportation, medical, high technology and defense sectors. He also provides market entry counseling to clients,
drawing on his broad public and private sector international experience and he designs and implements tailored
compliance and ethics programs for small- to large public companies. Drawing on his national security experience
he also assists clients (buyer and seller side) in national security reviews of foreign acquisitions through the
CFIUS/Treasury Department process. Mr. Christensen previously worked at two international law firms, and most
recently, served as the Science and Technology Advisor to the U.S. Mission to the OECD in Paris, France. He
currently serves on the international advisory board of the Reeves Center at the College of William and Mary.
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Corey Lee – leec@hunton.com
Corey is a partner in the Miami office of Hunton Andrews Kurth LLP. Corey has experience
conducting internal investigations, including investigations related to the Foreign Corrupt Practices
Act (FCPA), theft of trade secrets, healthcare fraud, False Claims Act and Racketeer Influenced and
Corrupt Organizations Act (RICO). He generally works with financial services, health care,
consumer and retail companies. Corey also regularly assists his clients with establishing FCPA
compliance programs, and provides FCPA compliance training to employees.
Corey also has an active commercial litigation practice, litigating matters arising from information
security and data breach incidents, contract disputes, class actions, business torts, securities
litigation, product liability litigation, and electronic discovery.
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Jonathan Stemerman – jms@elliottgreenleaf.com
Jonathan M. Stemerman is a Shareholder in Elliott Greenleaf, P.C.’s Wilmington office. He
concentrates his practice in the areas of corporate litigation, complex commercial litigation,
bankruptcy litigation and class action litigation. Mr. Stemerman previously served as a judicial
clerk to Justice Randy J. Holland of the Delaware Supreme Court from 2003 to 2004.
Mr. Stemerman has represented clients in numerous bankruptcy, corporate and complex
commercial litigation matters in Delaware and Pennsylvania. Mr. Stemerman also assists clients
with entity formation and counsels clients on corporate governance and compliance issues. He is
currently serving as an American Bar Association Business Law Section Fellow for the 2016-2018
term. Mr. Stemerman is Vice-Chair the E-Discovery Subcommittee of the ABA Business Law
Section’s Business and Corporate Litigation Committee, as well as the Vice-Chair of the Bankruptcy
Issues in LLCs Subcommittee of the ABA Business Law Section’s LLCs, Partnerships and
Unincorporated Entities Committee.
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QUESTIONS OR COMMENTS?
If you have any questions about this webinar that you did not get to ask during
the live premiere, or if you are watching this webinar On Demand, please do
not hesitate to email us at info@financialpoise.com with any questions or
comments you may have. Please include the name of the webinar in your email
and we will do our best to provide a timely response.
IMPORTANT NOTE: The material in this presentation is for general educational purposes only. It has been prepared primarily
for attorneys and accountants for use in the pursuit of their continuing legal education and continuing professional education.
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Foreign Corrupt Practices Act Compliance (Corporate & Regulatory Compliance Bootcamp)

  • 1. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Insert the cover image for this webinar on this slide entirely 1
  • 2. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Practical and entertaining education for attorneys, accountants, business owners and executives, and investors. 2
  • 3. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe DISCLAIMER The material in this webinar is for informational purposes only. It should not be considered legal, financial or other professional advice. You should consult with an attorney or other appropriate professional to determine what may be best for your individual needs. While Financial Poise™ takes reasonable steps to ensure the information it publishes is accurate, Financial Poise™ makes no guaranty in this regard. About this PowerPoint: if you are looking at this PowerPoint without the benefit of listening to the conversation that surrounded it then you are doing yourself a disservice. This PowerPoint was prepared in contemplation of being viewed in conjunction with listening to a one hour webinar on the topic 3
  • 4. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe MEET THE FACULTY Moderator: Rafael X. Zahralddin – Elliott Greenleaf Panelists: Guillermo Christensen – Ice Miller LLP Corey Lee – Hunton Andrews Kurth Jonathan Stemerman – Elliott Greenleaf 4
  • 5. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ABOUT THIS WEBINAR: Foreign Corrupt Practices Act Compliance The Foreign Corrupt Practices Act (“FCPA”) prohibits a U.S. company or person from bribing foreign government officials to obtain a business advantage. Along with this seemingly simple restriction comes accounting and record keeping requirements with which companies must comply. The FCPA requires the implementation of a compliance program which addresses FCPA concerns and establishes an FCPA corporate policy. This webinar covers the basics of the FCPA, including an introduction to the regulators, both the SEC and DOJ, and recent communications to the public regarding the FCPA from these regulatory bodies. The standards for a compliance program review is analyzed, including what makes a program current and effective as well as how often the program requires review. The role of a compliance coordinator is discussed, as is record keeping, training, and retaliation. Finally, meals and entertainment, gifts, travel, charitable contributions, and hiring will all be discussed with reference to recent government actions and legal decisions. 5
  • 6. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ABOUT THIS SERIES: Corporate & Regulatory Compliance Boot Camp This webinar series covers corporate and regulatory compliance as it relates to procurement and government contracting, the Foreign Corrupt Practices Act, data privacy and social media. The various episodes examine these topics from a company’s perspective, delving into compliance issues that pertain to specific company practices across industries and borders and impact companies of all sizes and types. Each episode is delivered in Plain English understandable to business owners and executives without much background in these areas. Yet, each episode is proven to be valuable to seasoned professionals. 6
  • 7. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe EPISODES IN THIS SERIES 6/6/19 Episode #1: Procurement & Government Contracting Compliance 7/11/19 Episode #2: Foreign Corrupt Practices Act Compliance 8/8/19 Episode #3: Data Privacy Compliance 7 Dates shown are premiere dates. All webinars will be available On Demand approximately 4 weeks after they premiere.
  • 8. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Episode #2: Compliance with U.S. Global Trade Laws: Foreign Corrupt Practices Act 8
  • 9. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe FOREIGN CORRUPT PRACTICES ACT • Telia – The Sweden-based telecommunications provider agreed to pay $965 million in a global settlement to resolve violations of the FCPA to win business in Uzbekistan. (9/21/17) • Halliburton – The company agreed to pay $29.2 million and a former vice president agreed to pay a $75,000 penalty to settle charges related to payments made to a local company in Angola in the course of winning lucrative oilfield services contracts. (7/27/17) • Michael L. Cohen and Vanja Baros – The former Och-Ziff executives were charged with being the driving forces behind a far-reaching bribery scheme that paid tens of millions of dollars in bribes to high-level government officials in Africa. (1/26/17) NOTE: Och-Ziff and other executives settled charges in 2016. • Orthofix International – The Texas-based medical device company agreed to pay more than $6 million to settle charges that its subsidiary in Brazil used high discounts and improper payments to induce doctors under government employment to use Orthofix products. (1/18/17) Source- https://www.sec.gov/spotlight/fcpa/fcpa-cases.shtml 9
  • 10. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe FOREIGN CORRUPT PRACTICES ACT (CON’T) • SQM - Chilean-based chemical and mining company Sociedad Quimica y Minera de Chile S.A. agreed to pay more than $30 million to resolve parallel civil and criminal cases finding that it violated the FCPA by making improper payments to Chilean political figures and others. (1/13/17) • Biomet - The Warsaw, Ind.-based medical device manufacturer agreed to pay more than $30 million to resolve SEC and Justice Department investigations into the company's anti-bribery violations in Brazil and Mexico. (1/12/17) • Cadbury Limited/Mondelez International - The global snacking business agreed to pay a $13 million penalty for FCPA violations occurring after Mondelez (then Kraft Foods Inc.) acquired Cadbury and its subsidiaries, including one in India that proceeded to make illicit payments to obtain government licenses and approvals for a chocolate factory in Baddi. (1/6/17) Source- https://www.sec.gov/spotlight/fcpa/fcpa-cases.shtml 1 0
  • 11. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe FOREIGN CORRUPT PRACTICES ACT (CON’T) • U.S. businesses with foreign contacts • Foreign subsidiaries of U.S. businesses • Select foreign companies and individuals • Catch-All - “any person” who commits bribery on a U.S. Territory 1 1
  • 12. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ISSUERS • Issuers are defined as a publicly traded company with 500 or more shareholders and more than $1 million in total assets • Domestic Issuers are responsible for the acts of officers, employees, agents, and other representatives • Domestic Issuers are responsible for subsidiaries, even if they don’t have a 50% ownership interest • FCPA accounting and reporting requirements for Issuers • Issuers have enhanced penalties for non-compliance 1 2
  • 13. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe DOMESTIC CONCERNS • Any business organized in the United States, U.S. citizen or resident • Domestic Issuers are responsible for the acts of officers, employees, agents, and other representatives • Domestic Issuers are responsible for subsidiaries, even if they don’t have a 50% ownership interest • Domestic Concerns are subject to anti-bribery rules, but not reporting requirements 1 3
  • 14. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ACCOUNTING AND RECORD KEEPING FOR ISSUERS • Issuers must keep detailed records • FCPA accounting provisions facilitate exposing illegal payments • Records 1. “Accurately and Fairly” reflect all of the issuer’s transactions and assets 2. “Reasonable Detail” 1 4
  • 15. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe BRIBERY OF FOREIGN OFFICIALS • Issuers, Domestic Concerns, and their agents or representatives are subject to the FCPA’s anti-bribery rules ✓ U.S. nationals and businesses (including foreign subsidiaries) can not engage in bribery of foreign officials ✓ Foreign nationals and businesses in the U.S. or it's territories can not engage in bribery of foreign officials 1 5
  • 16. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe BUSINESS SCENARIOS WITH ELEVATED RISK • Permitting / licensing E.g., payment to expedite a federal/regional/municipal/local permit to operate a certain type of facility; payment to obtain environmental or construction permit without conforming to all requirements • Government contracts E.g., payment to win or extend a government contract or to gain an advantage in negotiations with a government customer • Public procurement E.g., payment to gain an advantage in a tender (disqualify another bidder, influence tender specifications, obtain confidential tender information, etc.) • Customs E.g., payment to avoid required registration; payment to avoid or lower duties 1 6
  • 17. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe BRIBERY – FOREIGN OFFICIALS • Foreign Officials – intentionally broad definition 1. Not limited to public officials in foreign governments 2. Political parties, their officials, and all candidates for public office 3. Employees of state-owned or state-controlled corporations (e.g. universities, hospitals, utilities) 4. Officers and employees of public international organizations (organizations whose employees are treated the same as diplomats; e.g. World Bank, EBRD) 5. Intermediaries officially acting on behalf of a foreign official 6. Relatives or dependents of a foreign official • Significant risk in many countries (e.g. China): an employee of a seemingly private enterprise may be an “official” under the FCPA 1 7
  • 18. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe BRIBERY – IMPROPER PAYMENTS • “Payment” – not just money but anything of value • Includes promises, offers, and the authority to make payments in addition to payments that are completed • Foreign official does not have to receive the benefit of the payment • Can’t use a surrogate/intermediary – an indirect payment is a payment 1 8
  • 19. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe LEVEL OF KNOWLEDGE REQUIRED FOR PAYMENTS • Payor doesn’t need to know that a payment is or may be improper • “Conscious disregard of suspicious circumstances” • “Deliberate ignorance” of an illegal payment • “Corruptly” = intent “to induce the recipient to misuse his official or to influence someone else to do so.” • Voluntarily and with “bad purpose” in order to “obtain or retain business” 1 9
  • 20. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ALLOWABLE PAYMENTS • Foreign officials requesting or suggesting the bribe does not sanitize the transaction or reduce liability • Extortion payments are not subject to liability under the FCPA ✓ Narrow exception, does not include economic coercion • Payment made with conscious disregard of circumstances suggesting that a foreign official will benefit from it likely violates the FCPA 2 0
  • 21. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ALLOWABLE PAYMENTS (CON’T) • Must be carefully exercised as there are narrow exceptions 1. “Expedite or to secure the performance of a routine governmental action” - “Grease payments” allowed for expediting non-discretionary actions by minor officials 2. Payments explicitly allowed under the host country’s written laws 3. Reasonable and bona fide expenditures that are directly related to promotion or demonstration of products or the performance of a government contract are allowed (payments designed to cover travel and lodging incurred by government officials as part of normal business operations 2 1
  • 22. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe KEY RISK AREA - THIRD PARTIES 2 2 • Indirect payments are improper: e.g., through consultants, sales agents, customs agents, distributors, contractors, lawyers, etc. • Third parties play a role in the majority of all FCPA enforcement actions • Ignorance is not bliss – companies must act upon third-party “red flags.” E.g.: • Red flags are not a violation but warrant further inquiry, particularly depending on the third party’s role and the potential for improper activity 1. Shell company / inadequate staff 2. Little experience or insufficient qualifications in its line of work 3. Negative or questionable reputation in its market 4. Uses bank accounts in off-shore havens or unrelated countries 5. Bank accounts in off-shore havens or unrelated countries 6. Vague language in invoices to describe its services 7. An official requested the use of this third party 8. Is owned by or related to an official
  • 23. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe KEY RISK AREA – IMPROPER PAYMENT TYPES • Travel and Hospitality E.g., airfare (esp. first-class), hotel stays, expenses, and/or high per-diems, particularly in popular destinations or locations without a business nexus, or for family members even where a business purpose exists • Gifts and Entertainment E.g., extravagant gift-giving (luxury watches, shopping sprees, computer equipment, etc.), expensive wine-and-dine, or multiple gifts of smaller value • Charitable/political contributions E.g., donation to a charity associated with a government official’s relative or to a political party, seeking for the official to exercise any authority or influence 2 3
  • 24. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ENFORCEMENT • SEC ✓ Civil suits and enforcement of FCPA’s accounting requirements • DEPARTMENT OF JUSTICE ✓ Criminal prosecution • Agencies work together through referrals and will work together on some cases 2 4
  • 25. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe DISGORGEMENT (SEC ACT OF 1934) - TELIA • Telia Company AB's $965.6 million settlement September 2017 included disgorgement to the SEC of $457 million, the biggest disgorgement ever ordered in an FCPA enforcement action. • Telia won't actually pay the SEC $457 million in disgorgement. • About $40 million of the disgorgement will be satisfied by a forfeiture payment to the DOJ. • Up to $208.5 million will be offset for any confiscation or forfeiture payment Telia makes to Swedish or Dutch prosecutors. • So from the total disgorgement of $457 million ordered by the SEC, subtract $40 million for the DOJ forfeiture, and $208.5 million for the Dutch and Swedish payments. • That leaves disgorgement actually payable to the SEC of $208.5 million, or half of the ordered $457 million. Source http://www.fcpablog.com/blog/2017/9/25/telia-also-tops-our-new-top-ten- disgorgements-list.html 2 5
  • 26. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe PRISON SENTENCES AND YATES MEMO • Top Five Longest FCPA Related Prison Sentences 1. Joel Esquenazi: 180 months (2011) 2. William Jefferson: 156 months (2009) 3. Charles Paul Edward Jumet: 87 months (2010) 4. Carlos Rodriguez: 84 months (2011) 5. Douglas Murphy: 63 months (2005) Source- http://www.fcpablog.com/blog/2017/9/25/telia-also-tops-our-new-top- ten-disgorgements-list.html 2 6
  • 27. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe PRISON SENTENCES AND YATES MEMO (CON’T) • Companies will have to turn over information on involved individuals in order to get cooperation credit • All investigations will start with a focus on individuals in a company • Criminal and civil attorneys will work in lockstep on corporate cases, sharing information freely • Senior DOJ attorneys approve protection • Individual actions have to be resolved or have a plan before corporate actions can be resolved • Civil actions will be pursued against culpable individuals, even if they can’t pay a substantial fine 2 7
  • 28. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe YATES MEMO LIABILITY • Corporations are responsible for the criminal acts of their employees 1. Acting in apparent or actual scope of employment and 2. Intends in part to benefit the company 3. Even if the actions violate Coporate policy or express corporate order 4. If the employee is guilty the company is guilty • Corporation’s timely and voluntary disclosure is helpful • Corporation’s remedial actions are helpful • Corporate compliance, existence and effectiveness, also are evaluated • Upjohn – Corporate Miranda 2 8
  • 29. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe DODD-FRANK ACT – PRIVATE REFERRALS AND WHISTLEBLOWER PROTECTIONS • Whistleblowers, including foreign nationals, can apply for monetary rewards based on reporting bribery prohibited under the FCPA. • The Dodd-Frank Wall Street Reform and Consumer Protection Act mandates that the U.S. Securities Exchange Commission (SEC) pay whistleblowers monetary rewards (Ten to thirty percent of the amount recovered) if they provide the U.S. government with information that leads to the successful enforcement of the FCPA. • The Act is applicable even if bribes are paid in a foreign country and the whistleblower is a foreign national. • Anonymity is protected and there are anti-retaliation provisions that provide protection for employees who work in the United States 2 9
  • 30. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe WILDLIFE CRIMES (CASE STUDY ON CONCURRENT LIABILITY WITH OTHER FEDERAL AND INTERNATIONAL COMPLIANCE) • Wildlife trafficking and related wildlife crimes often involve FCPA violations. • Example, if a publicly traded cargo company bribed an official at a Liberian port so that the company could load ivory (or illegal timber, etc.) onto the ship without the official interfering, this would be a violation of the FCPA. 3 0
  • 31. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe WILDLIFE CRIMES (CASE STUDY ON CONCURRENT LIABILITY WITH OTHER FEDERAL AND INTERNATIONAL COMPLIANCE) (CON’T) • Whistleblowers worldwide can qualify for monetary rewards when reporting wildlife trafficking, illegal logging and illegal fishing. 1. The Lacey Act and the Endangered Species Act, direct the Fish and Wildlife Service, the National Marine Fisheries Service and the Departments of Interior, Commerce, Treasury and Agriculture to pay monetary rewards to persons who disclose original information concerning wildlife crimes that results in a successful enforcement action. 2. Whistleblowers may also qualify for rewards under the Foreign Corrupt Practices Act and the Act to Prevent Pollution from Ships/ Marpol Protocol. 3 1
  • 32. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe PENALTIES • PUBLICLY TRADED COMPANIES 1. Barred from doing business with government agencies or contractors 2. Export licenses suspended or debarred from the Commodity Futures Trading Commission 3. FCPA can trigger other enforcement actions from a variety of agencies • Willful violations can result in $25 million fines for accounting violations and $2 million for a violation of anti-bribery provisions • Civil penalties of up to $10,000 per violation • Defense costs are substantial 3 2
  • 33. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe SEC FCPA OPINION PROCEDURE • Issuers and Domestic Concerns can obtain an opinion of the Attorney General as to whether specific, prospective, not hypothetical, conduct on firm’s with the Department’s present enforcement policy regarding the anti-bribery provisions of the FCPA. Response is required by 30 days of the receipt of complete information in a request. 1. Must be submitted in writing 2. Actual and not hypothetical requirement does not require an executed contract 3. Only applies to the applicant parties 4. Requires a) Disclosure of all relevant and material information b) Authorized by the CEO and signed by a senior officer that has the operational responsibility for the conduct under review c) The Justice Department can require the CEO of the applicant and any subsidiaries to also attest to the truth of the submission • Does not excuse the applicant from the accounting requirements. 3 3
  • 34. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe PENALTIES • Accounting ✓ Willful violations by individuals can be up to $5 million and twenty years in prison for each violation • Anti-bribery ✓ Willful violations by individuals can be up to $100,000 and five years in prison for each violation • Civil penalties can be up to $10,000 per violation • Corporations can not indemnify or pay any fines levied against their employees or agents under the FCPA 3 4
  • 35. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe FCPA COMPLIANCE • Any payments to foreign officials must be scrutinized or avoided • Due diligence on foreign partners and surrogates is crucial (including continuous review of books and records) • Contracts must include FCPA compliance provisions, including that a violation is a material breach • Avoid cash payments (harder to track and reduce the ability to make transactions transparent) and keep fees reasonable to avoid making transfers suspect • Codes of conduct, education, reporting protocols, and careful screening of all employees, especially those working abroad 3 5
  • 36. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ABOUT THE FACULTY 3 6
  • 37. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Rafael X. Zahralddin – RXZA@elliottgreenleaf.com Rafael X. Zahralddin-Aravena is a Shareholder, Director, and Chair of his firm’s Commercial Bankruptcy and Restructuring Practice. He founded the Elliott Greenleaf Delaware office in 2007, which specializes in business law, as its first Managing Shareholder. He works as a litigator and advises businesses on issues of compliance, corporate formation, corporate governance, insolvency, distressed mergers and acquisition, commercial transactions, cyber law, and international and cross border issues. He is a National Association of Corporate Directors Governance Fellow. He has been lead counsel in several significant matters including serving as special litigation counsel in Washington Mutual, the largest bank insolvency in U.S. history. In the Nortel bankruptcies he successfully secured a settlement of more than $50 million for the permanently disabled former employees of the company. The firm and Mr. Zahralddin were named among the firms that received multiple awards in 2014, culminating in the Large Company Transaction of the Year Award from the Turnaround Management Association for their work in the AgFeed USA, Inc. bankruptcy, which involved the sale of the U.S. and China assets of a publicly traded company. 3 7
  • 38. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Guillermo S. Christensen – guillermo.christensen@icemiller.com Guillermo Christensen is a partner in the DC and New York offices of Ice Miller LLP and practices in the White Collar and Data Security and Privacy groups. Mr. Christensen is a former CIA intelligence officer and a diplomat with the Department of State with multiple international tours and domestic assignments including with the FBI. Guillermo has conducted numerous sensitive internal investigations on FCPA, OFAC and export control matters for clients in high-risk jurisdictions — he was worked investigations in the Middle East, including in Kurdistan/Iraq, Saudi Arabia, and Egypt; in Latin America (Mexico, Venezuela, Colombia, Ecuador, Argentina among many others), Asia and Africa. He also conducts in-depth diligence of third parties for clients, including several in Myanmar, Brunei, Malaysia, China, Chad, Angola, Nigeria, among others. His clients span the energy, transportation, medical, high technology and defense sectors. He also provides market entry counseling to clients, drawing on his broad public and private sector international experience and he designs and implements tailored compliance and ethics programs for small- to large public companies. Drawing on his national security experience he also assists clients (buyer and seller side) in national security reviews of foreign acquisitions through the CFIUS/Treasury Department process. Mr. Christensen previously worked at two international law firms, and most recently, served as the Science and Technology Advisor to the U.S. Mission to the OECD in Paris, France. He currently serves on the international advisory board of the Reeves Center at the College of William and Mary. 3 8
  • 39. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Corey Lee – leec@hunton.com Corey is a partner in the Miami office of Hunton Andrews Kurth LLP. Corey has experience conducting internal investigations, including investigations related to the Foreign Corrupt Practices Act (FCPA), theft of trade secrets, healthcare fraud, False Claims Act and Racketeer Influenced and Corrupt Organizations Act (RICO). He generally works with financial services, health care, consumer and retail companies. Corey also regularly assists his clients with establishing FCPA compliance programs, and provides FCPA compliance training to employees. Corey also has an active commercial litigation practice, litigating matters arising from information security and data breach incidents, contract disputes, class actions, business torts, securities litigation, product liability litigation, and electronic discovery. 3 9
  • 40. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe Jonathan Stemerman – jms@elliottgreenleaf.com Jonathan M. Stemerman is a Shareholder in Elliott Greenleaf, P.C.’s Wilmington office. He concentrates his practice in the areas of corporate litigation, complex commercial litigation, bankruptcy litigation and class action litigation. Mr. Stemerman previously served as a judicial clerk to Justice Randy J. Holland of the Delaware Supreme Court from 2003 to 2004. Mr. Stemerman has represented clients in numerous bankruptcy, corporate and complex commercial litigation matters in Delaware and Pennsylvania. Mr. Stemerman also assists clients with entity formation and counsels clients on corporate governance and compliance issues. He is currently serving as an American Bar Association Business Law Section Fellow for the 2016-2018 term. Mr. Stemerman is Vice-Chair the E-Discovery Subcommittee of the ABA Business Law Section’s Business and Corporate Litigation Committee, as well as the Vice-Chair of the Bankruptcy Issues in LLCs Subcommittee of the ABA Business Law Section’s LLCs, Partnerships and Unincorporated Entities Committee. 4 0
  • 41. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe QUESTIONS OR COMMENTS? If you have any questions about this webinar that you did not get to ask during the live premiere, or if you are watching this webinar On Demand, please do not hesitate to email us at info@financialpoise.com with any questions or comments you may have. Please include the name of the webinar in your email and we will do our best to provide a timely response. IMPORTANT NOTE: The material in this presentation is for general educational purposes only. It has been prepared primarily for attorneys and accountants for use in the pursuit of their continuing legal education and continuing professional education. 4 1
  • 42. Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™ Receive our free weekly newsletter at www.financialpoise.com/subscribe ABOUT FINANCIAL POISE DailyDAC LLC, d/b/a Financial Poise™ provides continuing education to attorneys, accountants, business owners and executives, and investors. Its websites, webinars, and books provide Plain English, entertaining, explanations about legal, financial, and other subjects of interest to these audiences. Visit us at www.financialpoise.com. 4 2 Our free weekly newsletter, Financial Poise Weekly, educates readers about business, business law, finance, and investing. To receive it simply add yourself by going to: https://www.financialpoise.com/newsletter/ Email addresses are never sold to or shared with third parties.