Mulligan Speaks in Hungary on FCPA Enforcement

February 6, 2014

Friedman Kaplan litigation partner Mary E. Mulligan discussed recent trends and developments in enforcement of the Foreign Corrupt Practices Act (FCPA) at two presentations in Budapest, Hungary on February 6, 2014. The presentations were organized by the American Chamber of Commerce in Hungary and the Hungarian Outsourcing Association.

Ms. Mulligan's presentations covered the Securities and Exchange Commission's increased role in FCPA enforcement; the use of additional statutes (such as anti-money laundering statutes) in enforcement proceedings brought by the SEC and the Department of Justice; the expansion of enforcement jurisdiction to include signatories of documents such as SEC filings, Sarbanes-Oxley certifications, and auditor letters; the importance of internal controls and accurate books and records; the need to monitor local consultants; new incentives for whistleblowers; and the FCPA implications of using U.S.-based computer servers. Ms. Mulligan was joined by Judit Budai and Zoltán Balázs Kovács, from Szecskay Attorneys at Law in Hungary, discussed Hungary's new whistleblowing regulations, as well as the increase in U.S. companies requiring that Hungarian companies certify FCPA compliance.

The first presentation, "The Foreign Corrupt Practices Act and the Sarbanes-Oxley Act or Why is the US Department of Justice and the SEC Interested in Your Business?: A Practical Guide for Companies," was held at the American Chamber of Commerce in Hungary from 9:00 a.m. to 10:30 a.m.

The second presentation, "Current Enforcement Trends Regarding the US Foreign Corrupt Practices Act and the Sarbanes-Oxley Act: Things for SSCs to Know," was held at the Hungarian Outsourcing Association from 2:00 p.m. to 4:00 p.m.