Lee Moran 
1-877-258-1877 ext.263 


Wednesday December 7, 2011 from 9:00 AM to 1:00 PM CST

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Hilton Houston Post Oak 
2001 Post Oak Blvd.
Houston, TX 77056-4401

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World Compliance - FCPA Houston Event 2011

Join us
Join us Wednesday December 7th at the Hilton Houston Post Oak  for a comprehensive look at the lessons learned over the past four years. Learn how DPAs and NPA can help guide your FCPA policy.  

Bribery Act and FCPA Summit

The UK Bribery Act has been described as “The FCPA on Steroids.”  For global companies, and for those which have business in the UK, the risks under the Bribery Act are real.

World Compliance is proud to sponsor the only US appearance in 2011 by the UK’s Bribery experts, Barry Vitou and Richard Kovalevsky, who work with corporate clients worldwide in the UK Bribery Act compliance and enforcement arena.

Joining Barry and Richard will be Tom Fox and Michael Volkov, who will address the global anti-corruption enforcement risks.

Learn from our expert team about:

  • The current enforcement activity of the UK’s Serious Fraud Office and the dangers of UK Bribery Act liability
  • The current risks under the UK Bribery Act
  • How the UK Bribery Act and the FCPA differ in scope and enforcement priorities
  • How global companies are designing compliance programs to comply with both the UK Bribery Act and the FCPA
  • How joint investigations and prosecutions by the SFO and the US Department of Justice and SEC pose significant risks to global businesses
  • The risks to global businesses, especially those involved in energy and private equity, in the rapidly expanding global enforcement network

The Houston event is sure to be unique and offers the rare perspective on the interaction of the UK Bribery Act and the FCPA

CLE credit for Texas is available to all attendees.

Join us and hear from Richard, Barry, Tom and Mike

9 AM – Opening remarks by Ryan Morgan AML/CA, CCEP - Anti Corruption Specialist, WorldCompliance

9:15 to 10:15 Tom Fox, Attorney - Tom Fox Law– “Lessons Learned from the last 4 years, understanding how DPAs and NPA can help you guide your policy” 

Panalpina-the 13 points of a best practices compliance program. The DOJ lays out its most current thinking on the minimum compliance program, with focus on foreign business partners, including
• Application of Compliance Policies to Foreign Business Partner
• Training on compliance program
• Ongoing advice and training
• Compliance terms and conditions in all contract

RAE and Joint Ventures.
• Transactions were executed in accordance with management's general or specific authorization;
• Transactions were recorded as necessary to (a) permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and (b) maintain accountability for assets;
• Access to assets were permitted only in accordance with management's general or specific authorization; and
• The recorded accountability for assets was compared with the existing assets at reasonable intervals, and appropriate action taken with respect to any differences.

Alcatel Lucent, Maxwell Technologies and Tyson Foods-Risk Assessments.
• Geography
• Interaction with types and levels of Governments.
• Industrial Sector of Operations
• Involvement with JVs
• Licenses and Permits in Operations
• Degree of Government Oversight
• Customs and Immigration

Johnson and Johnson-Enhanced Compliance Obligations.
• Compliance Department
• Gifts, Hospitality and Travel
• Complaints and Reports
• Risks Assessments and Audits
• Acquisitions
• Relationships with Third Parties
• Training
• Annual Certifications

Tenaris- actions which can lead to NPA rather than a DPA.
• Timely, voluntary and complete disclosure of all facts
• Real Time Cooperation with DOJ and SEC
• Voluntary and full investigation
• Extensive Remedial Efforts
• Commitment to enhanced compliance program
• Commitment to submit period monitoring reports to DOJ

10:15 to 10:30 Break

10:30 to 11:30 Michael Volkov, Attorney – Mayer Brown

Brief overview of FCPA, UK Bribery Act and relevant differences
• public and private bribery
• facilitation payments
• adequate procedures defense v. compliance credit
• extraterritorial jurisdiction

Identifying the Key issues from the FCPA and UK Bribery Act which may apply to your business and assessing current compliance program
• countries of operation
• industry
• level of government interactions, mergers and acquisitions
• joint ventures
• use of third parties
• gifts, meals, entertainment policies, charitable contributions and other issues

Principles for Compliance Program
• Designed for the business
• Need for buy in from business
• Problem Solving v. Dr. No
• Need to educate key gatekeepers to identify issues and raise them for resolution
• Documentation is the Key

Solving Specific Problems
• There is a solution for every problem
• Documentation
• Building a record to negate corrupt intent
• Good faith effort to comply is key to protecting people from going to jail (ostrich approach means jail)

Real World Problems
• Gift giving in China, Taiwan or Korea:  bribes do not have to be in money; negating corrupt
• Screening 3rd Party Agents: Large fees, Success fees, Close ties to government officials
• Defining “Due Diligence” – “reasonable inquiries”
• Damn the Torpedoes: Buying a company in 2 weeks with no pre-acquisition due diligence
• Securing a Permit in Afghanistan:  You know something is wrong – what do you do?
• Paying extraordinary Visa fees to ensure the Safety of Your Employees?
• Making Decisions on Less than Full Information – The Importance of Anti-Corruption Representations and Warranties
• My Fish is About to Rot:  Paying Customs Bribes or Destroying Your Product – Lessons in Extortion

11:30 to 12:30 Panel Discussion – applying lessons learned to your organization’s policies & procedures
• Jeremy Warren - Head of Financial Crime Prevention (FCPA) & Chief AML Officer EMEA Newedge Financial Group
• Panelists #2 & #3 to be announced

12:30 to 1 PM Question and Answer Session


Thomas R. Fox
General Counsel / Chief Compliance Officer
Thomas R. FoxThomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, Risk Management and international transactions. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. 
Tom writes and speaks nationally and internationally on a wide variety of topics, ranging from FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi-national US companies, insurance coverage issues and protection of trade secrets. Tom’s blog,, is one of the most well known blogs in the industry, and named one of the top 25 Business Law Blogs in 2010 by LexisNexis.



Michael Volkov
Michael VolkovMichael is currently a partner at Mayer Brown.  Michael Volkov is a former federal prosecutor with almost 30 years’ experience in a variety of government positions and private practice. Michael’s practice focuses on white collar defense, corporate compliance, internal investigations, regulatory enforcement matters and complex commercial litigation.

Before entering private practice, Michael served for more than 17 years as a federal prosecutor in the US Attorney’s Office in the District of Columbia; for 5 years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and for 6 years as a Deputy Assistant Attorney General and a Trial Attorney in the Antitrust Division of the US Department of Justice.
Michael has extensive trial experience and has been lead attorney in more than 75 jury trials, including some lasting more than six months. He has handled a number of high-profile criminal cases brought under a wide range of national and international laws, including those covering environmental, antitrust, international traffic in arms (ITAR), money laundering, online gambling, fraud, false claims and other complex crimes as well as the Foreign Corrupt Practices Act (FCPA) and other international bribery laws.

Barry Vitou
Barry heads Pinsent Masons LLP Corporate Crime team and works with corporate clients worldwide.  Barry has extensive experience advising clients in Russia and in representing clients throughout the Caribbean and Bermuda.

The Pinsent Masons team includes lawyers and in-house forensic accountants who only advise on corporate crime offering market leading compliance solutions and anti-corruption/fraud prevention strategies. The team advises on investigations, vigorously defends clients and liaises with regulators/prosecution agencies on self-reporting. The team can liaise with the SFO on a no names basis.

Richard Kovalevsky QC
Richard is a specialist in fraud and money laundering at 2 Bedford Row.
Richard Kovalevsky QC is regarded as a leading specialist in fraud and money laundering at the London Bar and is admitted to the BVI. (see Chambers Directory 2010, an independent guide to the legal profession in the UK which rates him as a leader in the fields of fraud and general crime).

He is regularly engaged by multinationals and individuals in pre-litigation and litigation settings concerning complex transactions with a potential criminal aspect. Recently, this has ranged from Russia and Nigerian telecoms cases through to advising directors concerning carbon credit frauds, national government infrastructure frauds, extremely complex banking frauds and the like.

Richard brings enormous intellectual firepower to every case with which he engages. He is known to think creatively and strategically to ensure the best possible outcomes for his clients. It is no exaggeration to state that many companies owe their continued existence to him and many men their freedom.


Lee Moran
Global Marketing Director