Philadelphia partner Mary Hansen and Chicago partner Dan Collins spoke at a Lloyd’s Market Association event on Wednesday, November 13.
Mary and Dan's presentation was titled, “The Foreign Corrupt Practices Act – What You Must Know.” The presentation gave an overview of the FCPA, concentrating on points participants should know when conducting business that may fall within the act’s wide scope.
The overview included:
· Anti-bribery provisions;
· Books, records and internal controls;
· Liability for acts of subsidiaries, coverholders, brokers and consultants; and
· Comparison with the UK regime.
The event also gave an up-to-the-moment briefing on U.S. sanctions, including the recently expanded laws applicable to the insurance industry, OFAC enforcement activity and NY Department of Financial Services interest in these matters.