New DOJ Playbook: Minimizing FCPA Risk, Targeted Enforcement, Investigations, Third-Party Management, Disclosures

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Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Corporate Law
- event Date
Thursday, November 13, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
This webinar will examine the updated DOJ approach to FCPA enforcement. The panel will explore what the recent guidance means in practice and how to translate it into concrete actions. The experts will discuss "what changed," then address risk assessment under new criteria, and delve into third-party management, an impactful organizational control area for improvement.
Faculty

Mr. Funk, a former Chicago federal prosecutor and conflict-deployed State Department attorney in Kosovo, has represented clients in many consequential and highly publicized cases in the United States and abroad. His clientele and cases reflect the high caliber of his work. Mr. Funk has represented companies of all sizes, as well as corporate executives and audit committees and boards; federal judges; Nobel laureates; NFL, NBA, and other professional sports franchises and athletes; A-list celebrities; countries and foreign agencies; diplomats; and US and foreign politicians and business leaders in civil litigation, internal investigations, and criminal matters. He successfully first-chaired dozens of federal and state civil and criminal trials, briefed and argued more than 20 federal and state appeals, directed more than 450 investigations, and argued more than 700 in-court evidentiary hearings and other contested proceedings. A fellow of the American Law Institute who is Chambers ranked Band 1 locally, as well as nationally and globally, and is a multiple "Lawyer of the Year" recipient, Mr. Funk uniquely received both the DOJ's prestigious Attorney General's Award for the nation's top trial performance and the US State Department's Superior Honor Award. The latter was awarded for his service as the DOJ Section Chief in Kosovo. Mr. Funk also received the ABA’s highest award for dedication to survivors of crime.
Description
The panel will address the cross-border complexities of third-party work: engaging state-owned enterprises, coordinating with distributors/agents, and working effectively with local counsel while maintaining books-and-records discipline. From this starting point, the panel covers investigations and self-disclosure, including scope of inquiry, documenting decision points, preserving evidence, and management/board coordination, followed by program training best practices and client counseling strategies.
Listen as our panel provides practitioners with practical insight and tools to counsel clients, triage risk, examine and address third-party lifecycle controls, understand and mitigate cross-border challenges, plan for investigations and disclosures, and design effective training plans.
Outline
I. Introduction: What changed?
II. Risk assessment under new criteria
III. Third-party management (screening, contracting, monitoring)
IV. Cross-border complexities (SOEs, distributors/agents, local counsel)
V. Taking actions: investigations, self-disclosure, and more
VI. Program training best practices
VII. Client counseling (boards, disclosure memos, remediation roadmaps)
VIII. Pracitioner takeaways
Benefits
The panel will review these and other key issues:
- Understanding the DOJ posture and enforcement priorities driving day-to-day investigations and oversight
- Examining and prioritizing high impact risks in this context
- Identifying and updating controls to minimize risk
- Planning responses, including investigations and document disclosure decisions
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