Hughes Hubbard Releases Fall 2024 FCPA Alert

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Dec. 4, 2024 – Hughes Hubbard released its Fall 2024 FCPA & Anti-Bribery Alert. For the 16th consecutive year, this highly respected and anticipated resource provides in-house counsel and compliance professionals with an analysis of the top trends and developments in the anti-bribery space, as well as an encyclopedic view of the past year’s enforcement actions and policy updates related to the Foreign Corrupt Practices Act (FCPA), and anti-bribery developments in France, Brazil and the UK, and at multi-national development banks.

Among the most important global cases, trends and enforcement actions that impacted anti-corruption law, multinational corporations, and individuals over the past year, the alert includes a comprehensive analysis of updates to the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs, multiple significant corporate resolutions, the new U.S. Foreign Extortion Prevention Act and its amendments, and developments in cases against individuals in both the U.S. and UK.

With these and other developments as context, the alert provides forward-looking guidance for corporations and individuals navigating the updated landscape. This includes recommendations regarding:

• Pre-acquisition anti-corruption due diligence and integration planning as a regular part of corporate M&A
• The need for strong internal controls
• The risk of unintended waivers of attorney-client privilege when cooperating with authorities
• Conducting appropriate due diligence and monitoring of business partners
• Carefully monitoring donations and sponsorships and gifts and hospitality
• Using executive compensation to promote ethical conduct
• Putting in place controls governing personal devices and the use of messaging applications
• Balancing data protection regulations with compliance needs