ENUpdate Autumn 2015
Newsletters | read time: 1 min
Leo Martin led delegates at London’s LegalConfex in September through the Anti-Corruption Boot Camp with thought-provoking contributions from fellow-panelists Omar Qureshi from Cameron McKenna and Sean Thomas of Hewlett Packard.
The panelists discussed a range of compliance challenges including the key difficulties in implementing robust ABC controls on the ground; where the Serious Fraud Office, Department of Justice, Securities Exchange Commission are going; is cross-country co-operation working?; what is the impact of non-compliance; what are the traps and risks when under investigation and when are procedures adequate?
Key points to note included:
- The need to set the right tone form the top in Joint Venture arrangements with the possible assistance of an independent supervisory board
- The importance of due diligence and common sense to make sure the right questions are being asked (e.g. Are our licences being acquired too quickly?) to avoid bribery being effectively outsourced via third parties
- Increased scrutiny of facilitation payments by the DOJ
