Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this episode of ‘All Things Investigations,’ host Tom Fox is joined by Mike DeBernardis to discuss the recent guidelines released by Deputy Attorney General Todd Blanche on the enforcement of the Foreign Corrupt Practices Act (FCPA).

They dissect the new memorandum, its implications for corporate investigations, and the focus on eliminating cartels and transnational criminal organizations. The conversation also delves into topics such as competitive advantage, the role of national security in FCPA enforcement, and the strategic implications for companies. The episode concludes with insights on how companies and their legal counsel should navigate these updated guidelines and prepare for a more expedited and focused investigation process.

Key highlights:


Overview of New FCPA Guidelines

Focus on Competitive Advantage

Prosecutorial Considerations

National Security and Strategic Business

Prioritizing Serious Misconduct

Advising Clients on FCPA Compliance


Resources:

Mike DeBernardis

Hughes Hubbard & Reed website

HHR Client Alert: DOJ Ends FCPA Enforcement Pause

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