Anti-Corruption and Trade Regulations: Identifying Common Elements and Streamlining Compliance Programs (Part One of Two)

The repercussions of violating trade sanctions, and the government’s focus on the issue, were recently highlighted with the $9 billion dollar fine of French bank BNP Paribas, which pled guilty in late June 2014 to transferring billions of dollars on behalf of Iran, Sudan and Cuba.  That case may be followed by others as the government investigates similar behavior by other companies.  Understanding how and when the FCPA and trade regulations intersect can help companies affected by both laws structure their compliance programs effectively and efficiently.  In a recent webinar hosted by Securities Docket, FCPA and trade regulations experts from KPMG and McGuire Woods came together to explain the details of the Office of Foreign Assets Control (OFAC) regulations and how they compare and contrast to the FCPA. In part one of this article series, KPMG Managing Director Charlie Steele details various OFAC penalties, discusses how OFAC calculates penalties and outlines three issues for companies to consider when negotiating with OFAC.  In part two, the panelists discuss the commonalities of FCPA and trade sanctions enforcement, detail potential anti-corruption and trade regulation synergies and provide four steps for developing a synergistic compliance program.

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