Brian Sharkey on "The Sunshine Act and the Impact on Global Enforcement"


Brian Sharkey spoke at ACI's 9th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry on Tuesday, April 28, 2015 at 2:30 PM.

"The Sunshine Act and the Impact on Global Enforcement: How to Satisfy Reporting Obligations and Assess the Risks Posed by the Disclosed Data"

Topic Highlights Included:

  • How US and foreign prosecutors are using data collected under Sunshine for FCPA and anti-bribery investigations
  • To what extent will Sunshine increase corruption enforcement as HCP spend disclosures expand globally
  • Conducting a risk assessment from the data disclosed: Spotting the red flags in your own data which the government will look at when determining potential FCPA violations
  • Clarifying reporting obligations under federal Sunshine laws for foreign affiliates: Determining what type of information to capture and how to report on it
  • Reporting by foreign parent companies for payments made within the U.S.
  • Update on the status of France’s transparency law and other new transparency mandates internationally.
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