Davis Polk partner John Reynolds was among the speakers at ACI’s 7th Annual New York Forum on Economic Sanctions. Reynolds spoke on the “What to Do when you Suspect a Violation: Tips for Internal Investigations and Determining the Value of a Voluntary Self-Disclosure” panel. Topics discussed included:
- Key analyses to determine the root cause of the issue (i.e. technical vs. human error)
- Identifying who should conduct the investigation, and coordinating their roles: In-house compliance and legal groups vs. outside counsel and forensic accountants
- Special considerations for internal investigations involving a foreign subsidiary or affiliate
- Reconciling investigative objectives with foreign privacy laws and blocking statutes
- Collecting and preserving documents in and outside of the US
- How to document your findings
- Do’s and don’ts for drafting a voluntary disclosure
- How voluntary disclosures impact penalty calculations
The program was held December 5-7, 2016, in New York.
For more information, please visit the event website.