TASA: TRACE Anti-Bribery Specialist Accreditation®
TASA: TRACE Anti-Bribery Specialist Accreditation® is a comprehensive and rigorous year-long training and accreditation program that offers a professional credential for anti-bribery compliance specialists. The accreditation enables professionals working in this growing field to distinguish themselves with demonstrated anti-bribery compliance expertise. The program is designed to be completed online and offers more than 100 courses taught by a world-renowned faculty of industry and subject matter experts. Candidates may self-select a specialization by region (LatAm, Europe, AsiaPac), subject matter (Business Integrity & Risk) and/or industry expertise (Oil, Gas & Energy, Financial Services, Life Sciences, Aerospace & Defense, Tech & Telecom) better preparing them to add real-world value to organizations. The accreditation is awarded by TRACE, the internationally recognized anti-bribery standard setting organization, and supported by the TASA Advisory Committee.
FCPA Year in Review
Date: Monday, 7 January 2019
Time: 1:00pm - 2:00pm EST
Speaker: Kara Brockmeyer, Partner, Debevoise & Plimpton LLP
Led by Kara Brockmeyer, Partner, Debevoise & Plimpton LLP and immediate former Chief of the FCPA Unit of the of the SEC’s Division of Enforcement, this webinar will provide an overview of key bribery and corruption enforcement trends in 2018 as well as lessons learned from the year’s most notable FCPA activity. Also offering insights into what’s driving bribery and corruption enforcement, Ms. Brockmeyer will also address what we might expect to see in terms of the SEC’s enforcement of bribery offenses in the months and years ahead.
Kara Brockmeyer is a litigation partner based in the firm’s Washington D.C. office. She is a member of the White Collar & Regulatory Defense and Strategic Crisis Response and Solutions Groups, where her practice focuses on representing companies and individuals in anti-corruption, fraud and related government investigations and internal investigations, as well as advising on compliance issues.
Prior to joining Debevoise in 2017, Ms. Brockmeyer served as the Chief of the SEC Enforcement Division’s Foreign Corrupt Practices Act Unit and directed a nationwide team of attorneys and forensic accountants investigating violations of the FCPA. During her tenure as chief of the unit, she oversaw many of the agency’s largest and most complex FCPA investigations. She was also one of the principal authors of the SEC-DOJ Resource Guide to the Foreign Corrupt Practices Act, which is widely considered the definitive government-issued guide on the FCPA.
Over a seventeen-year career at the SEC, including five years as an assistant director, Ms Brockmeyer led and personally conducted major investigations in all areas of SEC enforcement, including financial reporting, broker-dealer and investment adviser violations, and insider trading. She was also the founder and co-head of the division’s Cross-Border Working Group, an interdisciplinary group focused on addressing accounting fraud by companies based overseas.
Before joining the SEC in 2000, Ms. Brockmeyer was in private practice in Chicago, primarily focused on securities and complex commercial litigation.
Ms. Brockmeyer earned her J.D. from the University of Michigan Law School, magna cum laude, where she was also Note Editor of the Michigan Law Review. She received her B.A. from Williams College, cum laude.
She is a frequent speaker and commentator on anti-corruption and cross-border issues.
Anti-Corruption Compliance in Action
Date: Tuesday, 8 January 2019
Time: 1:00pm - 2:00pm EST
Speaker: Richard N. Dean, Partner, Baker & McKenzie LLP
During this session benefit from an overview of current trends and best practices in anti-corruption compliance. Addressing key points for risk exposure, best practices for building an effective anti-corruption compliance program as well as current enforcement trends, this session will also provide insight into key compliance challenges currently facing multinational companies, recommendations for achieving tone at the top and enforcing your compliance program across the organization.
Richard Dean is a partner in the Firm’s Washington, DC office and focuses on the US Foreign Corrupt Practices Act (FCPA) and related legislation, including US money laundering laws and their application to the activities of global companies in emerging markets such as the former Soviet Union, China, Indonesia and Latin America. Prior to joining Baker McKenzie, Mr. Dean worked at Coudert Brothers’ New York, Sydney, Moscow and Washington, DC offices, and was head of that firm’s Russia and Central Asia Practice from 1988 to 2005. He has an in-depth understanding of the key political, economic and cultural issues facing organizations doing business in these challenging markets.
Human Trafficking in the Supply Chain: Best Practice Recommendations for Complying With Federal, State and Foreign Requirements
Date: Tuesday, 29 January 2019
Time: 1:00pm - 2:00pm EST
Speaker: Michael R. Littenberg, Partner, Ropes & Gray LLP
Human trafficking remains an issue of global scale for companies across industries. Posing risks to global corporate operations across several fronts, benefit during this session from an overview of recent updates to the law specific to human trafficking at the global, US state and federal level. Providing practical suggestions for meeting regulatory compliance requirements, the session will also address related supply chain requirements outside of human trafficking that can pose exposure for multi-national corporations with global operations.
Michael R. Littenberg
Michael Littenberg is a partner at Ropes & Gray. As part of his practice, for almost 30 years, Michael has been active in advising leading public and private companies, asset managers and asset owners on ESG, corporate social responsibility and supply chain compliance matters, and he is widely viewed as one of the leading practitioners in this emerging area. Michael is the only U.S. law firm partner ranked in Chambers Global Business and Human Rights category, has been included for multiple years in various top influencer lists relating to CSR, conflict minerals and modern slavery compliance and has been a member of numerous advisory panels on a range of CSR issues.
In the ESG/CSR/supply chain compliance space, Michael advises clients on, among other things: compliance with a wide range of enacted, pending and proposed regulatory requirements, “soft law” instruments and industry and NGO codes of conduct, standards, frameworks and guidance; due diligence; risk and impact assessments; structuring and implementation of tailored compliance policies, procedures, programs and codes of conduct; public benefit corporations; impact and socially responsible investing; training; benchmarking; regulatory and voluntary disclosures and other communications; stakeholder engagement; and grievance mechanisms.
The Anti-Bribery Implications of the GDPR: Balancing Privacy and Transparency
Date: Thursday, 31 January 2019
Time: 1:00pm - 2:00pm EST
Speaker: Illya Antonenko, Data Protection Officer, TRACE International, Inc.
Led by Illya Antonenko, Data Protection Officer, TRACE International, Inc., this session will provide a top-level review of the fallout of the GDPR on anti-bribery compliance and explore areas of tension between the two compliance regimes. Specifically, Mr. Antonenko will analyze the practical impact of the GDPR on a company’s ability to conduct robust anti-bribery due diligence while also providing an overview of the GDPR’s jurisdictional reach under Article 3, member state implementation legislation, legitimization of the personal data processing under Article 6(1), data subject notifications under Articles 13 and 14, challenges posed by Article 10, and the potential impact of these issues on how you conduct business in an EU jurisdiction.
Mr. Antonenko is responsible for monitoring TRACE’s processes and operations for compliance with the EU General Data Protection Regulation and ensuring that the rights of data subjects are protected. He has diligently worked on resolving tensions between anti-bribery due diligence processes and the requirements of the GDPR.
Prior to joining TRACE, Mr. Antonenko practiced law for over fifteen years in a number of leading law firms in Washington, D.C. His practice included assisting clients with FCPA compliance matters and investigations, cross-border transactions, and general corporate issues. His career also included an in-house position as the associate general counsel of a leading manufacturer of critical flow control solutions, where he was primarily responsible for FCPA matters. While in-house, he worked closely with an independent compliance monitor and the U.S. Department of Justice in a post-FCPA enforcement context.
Mr. Antonenko received his Juris Doctor degree from Vanderbilt University Law School in 2002. He has been admitted to the state bars of District of Columbia and Maryland. He is a native speaker of Ukrainian and Russian.
Evaluating the Effects of the GDPR in Latin America
Date: Wednesday, 13 February 2019
Time: 12:00pm - 1:00pm EST
Speaker: Dra. Isabel Davara F. de Marcos, CIPP/US/E/CIPM & FIP, Davara Abogados
This TRACE webinar aims to explain the current impact that the General Data Protection Regulation (GDPR) has in Latin American countries and how such countries are developing or improving their legal frameworks to fit with the GDPR standards.
Hosted by Dra. Isabel Davara F. de Marcos, CIPP/US/E/CIPM & FIP, Davara Abogados, the webinar will provide an overview of the data protection laws in Latin America and their differences with the GDPR. According to such differences the speaker will carry out an identification of the key areas of compliance with GDPR and the main challenges that LATAM Countries face on this regard.
Finally, the webinar will include a set of proactive recommendations for companies that must comply with the GDPR or that seek to improve their data protection standards.
Accreditation Program Requirements
TASA has been designed to provide a comprehensive knowledge base for those seeking subject matter expertise in anti-bribery compliance. The accreditation process requires candidates to complete 20 hours of coursework along with passing two examinations to ensure knowledge retention. To attain accreditation candidates must complete the 20 hours of coursework and both Phase examinations within 12 months of entering the program. Divided into two substantive phases- Phase One: Fundamental Courses and Phase Two: Advanced Courses, there is a third optional phase of the program focused on specializations by industry, region and subject matter.
The TASA program provides a core set of fundamental anti-bribery compliance courses along with a broad range of regional and industry specific topics.
- Substantive Expertise: Courses focused on a wide range of anti-bribery fundamentals including but not limited to corporate compliance, third party due diligence, books and records provisions, law enforcement, cross-border investigations, international organizations, whistleblowers, compliance audits and forensic accounting.
- Regional Expertise: Courses focused on anti-bribery challenges in specific countries including, but not limited to, China, Vietnam, France, Italy, Spain, Venezuela, Mexico, Russia, India, Brazil, Nigeria and Myanmar.
- Industry Expertise: Courses tailored for the oil, gas & energy, aerospace & defense, technology & telecom, life sciences, financial services industries and the international development community.
Candidates are encouraged to design their own path of study of follow the standard two-phase structure detailed below.
Phase One: Fundamental Courses
Consisting of courses that address fundamental anti-bribery/anti-corruption concepts, Phase One provides candidates with a foundation for the material to be explored over the course of the TASA program. The fundamental courses include:
- Introduction to the FCPA: the History, the Law and the Lore
- Effective Internal Investigations – From Discovery to Disclosure
- FCPA Compliance in Action
- Gifts, Meals, Travel and Entertainment under the FCPA
- Due Diligence on Third Parties: Rationale, Requirements and Red Flags
- Navigating the Books and Records & Internal Control Provisions of the Foreign Corrupt Practices Act (“FCPA”)
- Toxic Transactions: Bribery, Extortion, and the High Price of Bad Business
- How to Promote Transparency and Inspire Ethical Behavior Through a Compliance and Ethics Framework
- Innovations and Challenges in Compliance Training
- TRACE Conflicts of Interest
- TRACE How to Say No
Program Phase Two: Advanced Courses
Building upon the foundation provided by the Phase One Fundamental Courses, Phase 2 engages the candidate into an exploration of advanced concepts with anti-bribery implications. The advanced courses are listed below:
- Managing Data Transfer & Conflict of Laws Risks Associated with Cross-Border Investigations and Litigation
- Anti-Bribery Compliance Audits: A Checklist of Essentials
- Contract Negotiation and Execution Detecting the Responding to bribery Risks
- FCPA Financial Risk Assessment
- What to do When a Company Receives a Dodd-Frank FCPA Whistleblower Letter
- Journey to the Center of Anti-Corruption Compliance: Past to Present and How this Context Influences Current Thinking
- Voluntary Self-Disclosure, cooperation and Remediation under the DOJ's Pilot Program
- SECs Increased Enforcement of Internal Controls
- Resolving Licensing, Sales, Tax and Customs Issues in High Risk Markets without Running Afoul of the FCPA
- TRACE Economic Sanctions Course
- TRACE Avoiding Trafficked Labor Course
(Optional) Phase Three: Industry, Subject Matter or Regional Specializations
Phase Three offers candidates to the opportunity to specialize on areas of anti-bribery compliance. The specialization pathways are listed below:
- By Region:
- Business Integrity & Risk
- By industry:
- Oil, Gas & Energy
- Financial Services
- Life Sciences Specialization
- Aerospace & Defense
Employees of TRACE Member companies benefit from complimentary access to all live and recorded TASA: TRACE Anti-Bribery Specialist Accreditation® webinars and discounted tuition.