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.