Navigating Uncertainty: Anticorruption Compliance in the Wake of US FCPA Enforcement Hiatus and Cartel Designation (June 5, 2025)
Recorded On: 06/05/2025
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In February, the Trump administration hit the pause button on US Foreign Corrupt Practices Act (FCPA) enforcement as an effort to level the playing field for U.S. businesses operating abroad. Before that, the administration designated Mexican cartels as foreign terrorist organizations, greatly increasing the risks to businesses operating in Mexico. How can or should your organization’s anticorruption compliance program adapt to the changes? What new strategic opportunities should you counsel your company to consider? What should you be prepared for in terms of future enforcement, given the five-year statute of limitations? Our in-house expert panelists, including a former US attorney and general counsel, will answer these questions and more as they critically examine the implications of the FCPA hiatus, the cartel designation, and increasing global regulations like the UK Bribery Act.
You'll walk away from this session equipped with strategies that safeguard corporate integrity while maintaining a competitive edge. Don't miss this opportunity to refine your playbook during this new era of anticorruption and anti-cartel compliance.
Generously Sponsored by Davis Polk
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William J. Hochul, Jr.
Of Counsel, White Collar Defense & Investigations
Davis Polk & Wardwell LLP
Bill advises clients on complex government and internal investigations, crisis management, communications strategy, risk mitigation and other matters. His work is informed by his wide-ranging experience as a United States Attorney, federal prosecutor, corporate general counsel and board member.
Before joining Davis Polk, Bill spent nearly 30 years with two different U.S. Attorneys’ Offices, including as the U.S. Attorney for the Western District of New York. As an AUSA, he conducted well over 50 jury trials. His work included high-profile cases in areas including international terrorism, labor racketeering, organized crime, public corruption, money laundering and cross-border smuggling.
Bill also spent several years as general counsel of a highly diversified multinational, privately held corporation. He is a frequent lecturer and has been a law school adjunct professor. Bill has also served as a director on multiple boards, including a large healthcare provider.
Daniel S. Kahn
Partner, White Collar Defense & Investigations
Davis Polk & Wardwell LLP
Dan represents companies and individuals in government enforcement matters, conducting internal investigations and in compliance matters, and has secured numerous favorable resolutions for clients with various enforcement authorities. Dan served for 11 years in senior roles at DOJ.
The Wall Street Journal described Dan as DOJ’s “most recognizable expert on the Foreign Corrupt Practices Act.” At DOJ, Dan was acting Deputy Assistant Attorney General of the Criminal Division and Chief of the Fraud Section, and Chief of the FCPA Unit. He supervised matters involving the FCPA, money laundering, and commodities, securities, healthcare and procurement fraud, and played a central role in developing enforcement policies on the FCPA, corporate enforcement, compliance and monitors.
Dan co-authored a treatise on corporate criminal investigations, and teaches Corporate Criminal Investigations at Harvard Law School and Global Anti-Corruption at Georgetown Law Center.
This program originally aired on June, 5, 2025. Please note that the on-demand format of this program is not eligible for CLE/CPD credit.
