How the SEC Has Changed Due Diligence: The FCPA, Internal Controls and Third Parties

How the SEC Has Changed Due Diligence: The FCPA, Internal Controls and Third Parties

Thursday, 27 February 2020 | 1:00 PM

During this session, Bill Steinman will explore how recent SEC enforcement actions have used the FCPA’s internal controls provision to raise the bar on how companies engage and monitor distributors and resellers. In the last eighteen months, the SEC has applied the internal controls provision and its strict liability standard to impose heightened burdens on how companies work with their third parties. An additional benefit of this discussion, Mr. Steinman will also provide practical suggestions for revisiting due diligence requirements, shoring up your approach to training and practical approaches for successfully managing third party risks.


William Steinman

Senior Partner
Steinman & Rodgers LLP

William B.F. Steinman, Senior Partner, Steinman & Rodgers LLP - Mr. Steinman’s practice focuses primarily on FCPA issues in the aerospace and defense, food and beverage, and energy industries.  He has extensive practical experience with the engagement of overseas sales representatives, consultants, distributors/resellers, and logistics service providers. Mr. Steinman is frequently called upon to assist clients with respect to internal investigations, compliance reviews, and risk assessments.  He regularly advises clients in the negotiation and fulfillment of foreign offset requirements. He has also represented sovereign governments in West Africa and the Caribbean regarding anti-corruption and development matters. Prior to establishing Steinman & Rodgers LLP more than a decade ago, Mr. Steinman was the head of the international practice group at a major U.S. law firm.


Mr. Steinman is a contributing editor of the FCPA Blog, an online source for FCPA news and developments. He is an adjunct professor at Catholic University’s Columbus School of Law and Roger Williams University School of Law, where he teaches advanced FCPA seminars, and at George Washington University Law School, where he teaches a course on international negotiation.


He previously served as Vice Chair of the ABA International Section’s Aerospace and Defense Industries Committee. Between 2003 and 2007, Mr. Steinman served on the Board of Directors of TRACE International. In 2011, Mr. Steinman was a delegate to the World Justice Forum in Barcelona, Spain. He is a frequent speaker on anti-corruption matters, and has addressed ACI’s annual International Conference on the FCPA, the Aerospace General Counsels Association, and the International Forum on Business Ethical Conduct for the Aerospace and Defense Industry.  His views on anti-corruption matters have been sought by numerous legal and compliance publications, including Law360, the Legal Times, and Corporate Counsel, and Mr. Steinman has appeared as a guest on MSNBC to discuss anti-corruption laws.


Steinman & Rodgers LLP is a boutique law firm in Washington DC and New York focused exclusively on international anti-corruption matters, with an emphasis on compliance.  Steinman & Rodgers LLP is a certified woman-owned small business.

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