In the Episode, I am joined by Mike DeBernardis, Counsel at Hughes Hubbard, in the firm’s Washington office and a member of the firm’s Anti-Corruption and Internal Investigations and White Collar & Regulatory Defense practice groups. He represents corporate and individual clients in criminal, civil and administrative enforcement matters, including matters involving the Foreign Corrupt Practices Act and securities and accounting fraud. In this episode we take a deep dive into the DOJ’s 2020 Update to the Evaluation of Corporate Compliance Programs and DOJ and SEC FCPA Resource Guide, 2nd edition.
Some of the highlights include:
- What were the top changes DeBernardis observed in 2020 Update to Evaluation of Corporate Compliance Programs?
- What were the top changes for you in FCPA Resource Guide, 2nd edition?
- How should one read the Resource Guide, 2nd with the 2020 Update? In conjunction, separately or in some other way?
- Is there any significance to the two documents being released so close together in time?
- Should you advise clients to do anything different because of these documents?