A Review of the Resource Guide to the U.S. FCPA, Second Edition


A Review of the Resource Guide to the U.S. FCPA, Second Edition

Wednesday, 12 August 2020 | 11:00 AM EDT (4:00 p.m. GMT+1)

On 3 July 2020, the U.S. Department of Justice and Securities and Exchange Commission released the Second Edition of its Resource Guide to the U.S. Foreign Corrupt Practices ActOriginally published in November 2012, the Guide is designed “to provide companies, practitioners, and the public with detailed information about the statutory requirements of the Foreign Corrupt Practices Act (FCPA) while also providing insight into DOJ and SEC enforcement practices through hypotheticals, examples of enforcement actions and anonymized declinations, and summaries of applicable case law and DOJ opinion releases.”[i]


During this session benefit from a top-level overview of revisions made in the Second Edition of the Guide, including updates driven by recent changes to case law as well as DOJ and SEC policies including the definition of the term “foreign official,” the jurisdictional reach of the FCPA, DOJ’s FCPA Corporate Enforcement and Anti-Piling on policies, the Criminal Division’s Evaluation of Corporate Compliance Programs and more.


As part of the session Billy and Sarah will conclude with practical recommendations for MNCs seeking to evaluate how internal compliance policies/program should be updated in light of the updated Guide.


Time will be allotted for Q&A.


[1] (U.S. Department of Justice, 2020)


CLE credits are available for this webinar in the following states – TX, VA, NY, NJ, CA. Additional instructions on how to obtain CLE credits will be provided during the webinar.


Billy Jacobson

Partner, Allen Overy

Billy focuses his practice on FCPA and white collar enforcement, representing corporates, individuals, and financial institutions. Billy has over 25 years of experience, having served as the Chief Compliance Officer and Co-General Counsel of a global oilfield services company, as a federal prosecutor -- including as Assistant Chief for FCPA Enforcement in DOJ’s Fraud Section, and in private practice. Billy’s expertise both in corporate compliance and corporate criminal defense is a rare combination that serves clients well.


Billy is Chambers-rated for both FCPA and white collar enforcement generally.


Billy’s practice currently includes the representation of a large international engineering and construction company being investigated for FCPA and UK Bribery Act violations by the DOJ, SEC and UK SFO; the representation of companies facing potential sanctions by the World Bank; serving as compliance counsel for several companies and private equity firms; the representation of individuals in connection with the VW emissions investigation cases; and the representation of several individuals in various FCPA investigations.


Billy recently completed the monitorship of Braskem SA, a large multi-national petrochemical company based in Brazil that settled enforcement actions in 2016. He was appointed as an independent compliance monitor by the DOJ, SEC and the Brazilian MPF. That monitorship concluded successfully and on schedule.


Billy is considered a thought leader in the industry, having spoken extensively on compliance and investigation topics.

Sarah Foley

Compliance Specialist, Allen Overy

Sarah is highly skilled in global investigations, fraud, and anti-corruption compliance matters. She leverages her in-house experience in senior compliance roles to assist organizations with developing, implementing, and setting the strategic direction for global ethics and anti-corruption compliance programs. Sarah has conducted compliance trainings, investigations, and risk assessments throughout Africa, Asia, Canada, Europe, Latin America, Mexico, Russia, the Middle East, and the United States. She also has led global compliance due diligence and integration activities.

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