Global Anti-Corruption Compliance and Enforcement: Strategies for Managing the Risks Posed by Third Parties, Business Combinations, and Allegations or Evidence of Misconduct

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Commercial activity reaches across national boundaries more than ever before. This business reality, along with an increased enforcement focus on corporate wrongdoing, has led to an explosion of enforcement actions under the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. How can companies, and practitioners that advise them, manage the risks and ensure that appropriate compliance programs are in place, particularly regarding third parties, business combinations, or allegations or evidence of misconduct?

The faculty presenting this program will address this question and provide guidance regarding anti-corruption laws that impact many areas of legal practice including corporate law, white collar crime, international trade, securities regulation, extractive industries such as oil, gas and mining, the defense industry, and pharmaceutical, medical device, and other health care-related areas of the law.

Educational Objectives:
• Understand the cross-border nature of global anti-corruption compliance and enforcement.
• Learn how to manage risk when utilizing third parties and business combinations.
• Develop an understanding of how to develop third-party due diligence procedures and investigations in the face of allegations or evidence of misconduct.
• Find out about the key points related to the design and implementation of effective global risk-management strategies and programs.

Who would benefit most from attending this program?
Practitioners involved in offering counsel, representation, and compliance advice related to the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws, as well as legal and compliance professionals at multinational companies would benefit from attending.



Kevin Abikoff, a partner with Hughes Hubbard, is Chairman of his firm's Anti-Corruption and Internal Investigations practice group, Co-Chairman of the Securities Litigation practice group, and a member of the Executive Committee. He regularly advises clients across myriad industries and geographic regions on the full range of anti-corruption issues. Mr. Abikoff was appointed as monitor for Innospec by the U.K. Serious Fraud Office, U.S. Department of Justice, and U.S. Securities & Exchange Commission and, with approval from U.S. Office of Foreign Assets Control, led the engagement for a multinational oilfield services company in its post-DPA activities, and was appointed by the United Nations as a monitor. He has travelled the world many times over to conduct internal reviews and meet with a broad range of business partners including hundreds of agents, distributors, joint venture partners, and other third parties. Mr. Abikoff is also the first U.S. member of the Certification Committee of ETHIC Intelligence, a Paris-based group that assesses corporate anti-corruption policies and processes and certifies that those policies and processes comply with international legal standards and best practices, and whose certifications are validated by the Basel Institute on Governance.


Mr. Abikoff earned a J.D. from Columbia Law School, where he was a member of the Law Review and a Harlan Fiske Stone Scholar, and a B.A., summa cum laude, from Boston University. He is admitted to practice in the District of Columbia, Texas, and Pennsylvania.



John Wood is a partner at Hughes Hubbard who focuses his practice on providing compliance advice to corporations and conducting internal corporate investigations. He served as an Independent Professional Ethics and Internal Compliance Expert approved by the United Nations for a multinational company seeking reinstatement as a U.N. vendor and represents a variety of large multinational companies in connection with all phases of anti-corruption compliance-related activities. Prior to joining Hughes Hubbard, Mr. Wood served as United States Attorney for the Western District of Missouri, the chief federal law enforcement official for that district. In that role, he oversaw a staff of 128 employees and a broad range of federal prosecutions, including the largest corporate fraud and securities investigation in the district's history. Mr. Wood previously held other high-level positions with the Department of Justice, including Deputy Associate Attorney General and Counselor to the Attorney General. He also served as Chief of Staff for the U.S. Department of Homeland Security.


Mr. Wood earned a J.D., magna cum laude, from Harvard Law School, where he served as Articles Chair for the Harvard Law Review, and a B.A., with honors, from the University of Virginia. He is admitted to practice in the District of Columbia and Missouri.



Michael Huneke is a Senior Associate at Hughes Hubbard, with significant experience conducting FCPA investigations and compliance reviews and representing individuals accused of white-collar offenses. Currently, Mr. Huneke is serving as the liaison between a multinational industrial manufacturing company and the compliance monitor imposed as part of that client’s recent settlement with the World Bank's Integrity Vice Presidency. He has significant experience performing anti-corruption and FCPA due diligence reviews as well as numerous investigations in connection with the U.S. Securities & Exchange Commission, the U.S. Department of Justice, and congressional inquiries. He has experience with investigations across a variety of industries and nations around the globe and with assisting American and European clients in designing, administering, and maintaining anti-corruption policies and compliance programs. Prior to joining Hughes Hubbard, Mr. Huneke clerked on the United States District Court for the Eastern District of Virginia.

Mr. Huneke earned a J.D. from Harvard Law School and a B.A., with high distinction, from the University of Virginia. He is admitted to practice in the District of Columbia and Virginia.