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Join host Alexandra Addison, President & Founder of TRACE, on Bribe, Swindle or Steal as she explores the world of financial crime—corruption, fraud, money laundering and sanctions—and what motivates people to break the law, how wrongdoers cover their tracks and what can be done to put a stop to the looting through interviews with experts in the field.
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At the 2025 TRACE Annapolis Forum, Nicola Bonucci, Associate Professor at Paris Cité and former General Counsel of the OECD, reflects on 25 years of the OECD Anti-Bribery Convention and the evolving challenges of global enforcement. From uncertainties around FCPA guidance, political influence, and uneven implementation, to questions about the U.S.'s continued leadership in anti-bribery efforts, Nicola highlights the risks companies face in an increasingly unpredictable landscape—where cross-border investigations, bribe solicitation, and public scrutiny are on the rise.
This episode was originally published on 24 September 2025.
Kara Brockmeyer, a partner in Debevoise & Plimpton's Washington office and former Chief of the SEC's FCPA Unit, discusses some changes she's observed in the implementation of compliance programs with much of the world in lockdown. She also describes the pace of investigations now that DOJ and SEC lawyers are working remotely and she wraps up with a few predictions about what we might see in this field post-pandemic.
Darshak Dholakia, a partner in Dechert's Washington office, provides a timely overview of the current Committee on Foreign Investment in the United States (CFIUS) approach to foreign investment in the US, comparable laws of other countries and how scrutiny of healthcare and biotechnology sectors may increase in light of the COVID-19 pandemic.
Bill Steinman--of Steinman & Rodgers--takes us back to 2014 and the Eleventh Circuit's very fact-specific analysis of what constitutes a "foreign official" under the FCPA.
Melissa Duffy, a partner at Dechert LLP focused on international trade matters, provides an excellent review of the current status of the movement of goods into and out of the United States by air, land and sea. Melissa also addresses relevant tariffs, including recent exemptions, and restrictions by other countries on the export of their own critical medical supplies and equipment. Melissa wraps up with some very practical strategies for companies on managing the movement of goods in these uncertain times.
Jeff Clark—a partner with Willkie, Farr & Gallagher—discusses the novel aspects of the 2016 Och-Ziff bribery case, including the claim for restitution under the Mandatory Victims Restitution Act.
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