Conducting Effective Anti-Corruption Risk Assessments: An Interview with David Simon, Partner at Foley & Lardner LLP

Objectively, a best-in-class compliance program must be reasonably tailored to the risks actually faced by a company, but determining how to realistically assess the risks it faces is a subjective process.  There is no government-promulgated method for conducting a sufficient anti-corruption risk assessment; thus companies with global operations are left with the imperative of conducting risk assessments, but little authoritative guidance for doing so.  In an effort to bridge the gulf between demand and supply of best practices, the Anti-Corruption Report is publishing a series of interviews with FCPA experts in different disciplines on effective techniques for conducting anti-corruption risk assessments.  This article, the first in the series, contains our interview with David Simon, partner at Foley & Lardner LLP.  Simon has extensive anti-corruption experience, including representing Carlos Rodriguez in his challenge to the government’s interpretation of “foreign official” in the Haiti Teleco case; that case is currently in front of the Eleventh Circuit.  See “A Hot Bench Hears Oral Arguments in Historic Challenge to the Definition of ‘Foreign Official’” (Oct. 23, 2013).

To read the full article

Continue reading your article with an ACR subscription.