Reed Smith Client Alerts

We recently gathered a group of regulatory attorneys from across Reed Smith to provide a rundown of the key trends to watch for in Q2 2024 – if you missed the webinar, you can access the recording on demand.

Please see a short summary of our top takeaways below and look out for an invite to the next installment of this quarterly series – we hope you can join us!

Anti-corruption enforcement in China

  • Tackling corruption remains a top priority for China in 2024, with an increasing emphasis on coordinated action by government agencies. The current anti-corruption drive focuses on strategic sectors, such as health care and finance.
  • Consistent with historical trends, China continues to be the country most frequently implicated in Foreign Corrupt Practices Act (FCPA) corporate enforcement actions. Improper payments disguised as gifts, entertainment or travel expenses, as well as schemes involving third-party intermediaries, were prominent features of recent FCPA actions involving conduct in China.
  • Companies should proactively identify anti-bribery and corruption risks under both domestic and applicable foreign laws (such as the FCPA) and devote more resources to ensure adequate compliance training and oversight, especially for sensitive business activities.

DOJ pilot program to reward whistleblowers

  • Provides financial incentives to individuals to report corporate wrongdoing before company does so or is even able to do so. Companies must weigh the prospect of an employee reporting to the Department of Justice (DOJ) against the need to engage in fact-finding before self-reporting any potential wrongdoing.
  • Employees may be less willing to use internal compliance reporting resources, such as anonymous hotlines.
  • May be a powerful tool in FCPA cases where significant obstacles often exist in collecting foreign evidence.