Cheryl Scarboro presents TRACE&rsquos annual FCPA Year in Review webinar and we listen in for today&rsquos podcast. Cheryl was Associate Director in the SEC&rsquos Division of Enforcement for almost twenty years and served as its first ever Chief of the FCPA Unit. She is now a partner in Simpson Thacher & Bartlett&rsquos Washington DC office.

Peter Solmssen joins the podcast to talk about his work, together with a group of experts, in support of the OECD Working Group on Bribery&rsquos revised Recommendation relating to settlements. He discusses how &ldquoindividual heroism&rdquo by prosecutors should not be required to reach settlements, and he shares his thoughts on the benefits the revised Recommendation will bring not only to companies, but also to prosecutors and to the larger goal of reducing corruption.

Nicola Bonucci, former Legal Director at the OECD and now a partner at Paul Hastings in Paris, joins the podcast to discuss the 2021 OECD Anti-Bribery Recommendation announced in November. We also chat about the challenge of advancing an international consensus on anti-corruption enforcement amongst Working Group on Bribery members hailing from different legal systems.

Dan Kahn joins the podcast to discuss his time at the U.S. Department of Justice, including as Chief of the FCPA Unit, and his recent transition back to private practice as a partner in the White Collar Defense and Investigations practice in Davis Polk&rsquos Washington office. Dan discusses recent trends, the new guidance announced by Deputy Attorney General Lisa Monaco and some approaches to pursuing demand-side bribery.

Hentie Dirker, Chief Integrity Officer with SNC Lavalin, speaks to Jonathan Drimmer of Paul Hastings about building a culture of compliance in the aftermath of a bribery scandal. (This episode was originally published in August 2019.)