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Anti-Bribery and Third-Party Compliance in 2014: What Is Required of Multinational Companies and Their Global Business Partners?

Anti-Bribery and Third-Party Compliance in 2014: What Is Required of Multinational Companies and Their Global Business Partners?
Product Code - LGN246
Speaker(s): Amy L. Sommers, K&L Gates LLP; Alexandra Wrage, TRACE International, Inc.
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Actions taken to enforce the U.S. Foreign Corrupt Practices Act (FCPA) are steadily increasing in number, with a steep rise in corporate fines over the past year and dozens of cases reportedly in the pipeline. Many FCPA cases involve conduct by third parties which highlights the importance of screening suppliers, distributors, consultants, agents, and service providers. Companies of all sizes, however, continue to struggle with third-party due diligence, with many recognizing due diligence as their company’s most significant anti-bribery compliance challenge.

This program will address third-party bribery risks as well as other supply chain risks, including forced and trafficked labor and conflict minerals usage, and will provide practical guidance on avoiding due diligence pitfalls and applying a risk-based and collaborative approach to screening third parties. The faculty will also discuss industry best practices and provide tools and tactics that companies and the counsel advising them can use to effectively sort third parties by risk and reduce due diligence costs.

Educational Objectives:

• Learn how to detect and respond to anti-bribery and third party risks.

• Gain insight into the mechanics of a credible third-party risk sorting model that controls costs and ensures compliance with regulatory expectations.

• Discover how to apply a risk-based and collaborative approach to due diligence that reduces screening costs.

Who would benefit most from attending this program?

Corporate counsel; compliance and ethics officers; directors of internal audit; those involved with corporate audits and investigations; and outside counsel specializing in FCPA/corporate compliance, white collar crime, and corporate governance.

Program Level: Intermediate
Prerequisite: A general understanding of compliance issues, especially those faced by clients operating in foreign markets.
CPE Delivery Method: Group Internet-Based Live
Field of Study: Specialized Knowledge and Applications
Recommended CPE Credit: 1.5 credits
Anticipated CLE Credit: 1.5 credits (may vary based on from which jurisdiction requested)

For additional information, please see the “CE Credit” tab.

Amy L. Sommers, K&L Gates LLP; Alexandra Wrage, TRACE International, Inc.

Amy L. Sommers, K&L Gates LLP
Amy Sommers is a partner based in her firm’s Shanghai office, where she works closely with clients in developing strategies for compliance with the FCPA and PRC anti-bribery laws and provides global solutions for clients facing the challenges of increasingly complex regulation and intensified global enforcement. Her strong skills in corporate structuring, governance and operations issues in China make her a valued resource to the clients she counsels. A former Chair of the American Bar Association’s China Committee, Ms. Sommers is a frequent speaker and commentator on China issues. Her involvement in China goes back over 25 years, when she first started studying Mandarin, later developing deep appreciation of China's history, politics, culture and legal system. Her clients benefit from her ability to bring these insights to bear on their strategic China projects.

Ms. Sommers regularly counsels clients on strategic investment, whether through “green fields” investment or by M&A activity, in regulated or restricted sectors of the PRC economy, where familiarity with not only the legal requirements but also the policy concerns underlying the regulatory environment, are vital. Clients also seek her advice on ongoing issues relevant to the success of their China businesses, such as distribution, manufacturing and intellectual property licensing arrangements.

Ms. Sommers earned a J.D. from the University of Washington School of Law and a B.A. from the University of Washington. She is admitted to practice in Washington.

Alexandra Wrage, TRACE International, Inc.
Alexandra Wrage, president of TRACE International, is the author of Bribery and Extortion: Undermining Business, Governments and Security and the host of a training DVD entitled Toxic Transactions: Bribery, Extortion and the High Price of Bad Business. She has written three compliance guidebooks and is a guest blogger for the Huffington Post. She speaks frequently on topics of international law, anti-corruption initiatives, and the hidden costs of corruption.

Ms. Wrage formerly served on the Independent Governance Committee (IGC) of the Fédération Internationale de Football Association (FIFA), football’s governing body. She has previously served as Chair of the Anti-Corruption Committee of the ABA’s International Section and Chair of the International Legal Affairs Committee of the Association of Corporate Counsel. She has participated in anti-bribery working groups with the OECD and the UN Global Compact. Ms. Wrage was named one of the “Canadians Changing the World” by the Toronto Globe and Mail in 2011 and a Maryland Daily Record “Most Admired CEO” for 2012.

Prior to founding TRACE International, Ms. Wrage was international counsel at Northrop Grumman, where she was responsible for managing and improving the company’s FCPA program, including policy revisions, training, monitoring, and board briefings.

Ms. Wrage studied law at Kings College, Cambridge University. She is a member of the Maryland and District of Columbia bar associations.

This program’s CLE-credit eligibility varies by state. Bloomberg BNA is an accredited provider in the states of New York*, California, Pennsylvania, Texas and Virginia, and most other jurisdictions grant CLE credit on a per-program basis. At this time, Bloomberg BNA does not apply directly to the states of Florida, Rhode Island, Montana and Hawaii although credit is usually available for attorneys who wish to apply individually. Additionally, the following states currently do not grant credit for Bloomberg BNA OnDemand programming: Arkansas, Ohio, Nebraska, and Delaware. All requests are subject to approval once the live webinar has taken place or the customer has viewed the OnDemand version. Please contact the Bloomberg BNA accreditations desk if you have specific questions that have not been addressed.

*Bloomberg BNA is an accredited provider in New York for experienced attorneys only.

Hardship Policy
For information regarding Bloomberg BNA’s Hardship Policy, please visit the Continuing Education Information page.

Individual programs, subjects, and formats may not receive credit in some states and there may be specific rules regarding who may earn credit or the maximum number of credit hours that may be earned with specific formats. For specific questions, contact your state MCLE regulatory entity for specific questions about your MCLE rules or visit the American Bar Association’s website for general information on accreditation.

If you have further questions regarding a specific state or how to file for CE credit, please contact Bloomberg BNA customer service at 800-372-1033 and ask to speak to the CLE Accreditation Coordinator or send an email to