FCPA, UKBA and Other Four-Letter Words: Anti-Corruption Laws in a Global Economy

Susan Friedman, Senior Vice President & Employed Lawyers Practice Leader, Marsh Inc, USA
Machua Millett, Senior Vice President, Marsh Inc, USA

Few subjects receive as much attention in legal, compliance and accounting circles these days as the United States Foreign Corrupt Practices Act (the “FCPA”), the United Kingdom Bribery Act (the “UKBA”) and other foreign and international anti-corruption laws. However, while familiarity may breed contempt, presumed familiarity with anti-corruption laws is more likely to breed a regulatory investigation, subsequent regulatory proceeding, follow-on class action and derivative suits, and uninsured legal, accounting, consulting and settlement bills in the tens of millions to billions of dollars. The amount of attention paid to FCPA compliance and investigation defense issues is necessary because the incidence of anti-corruption issues and the costs of developing policies and procedures, conducting investigations and resolving regulatory inquiries and related court actions continues to escalate.

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USA Anti-Corruption Insurance January 2012 Vol. 5, No. 18, Winter 2012

Susan Friedman


Susan F. Friedman serves as a Senior Vice President, Claims Advocate, Employed Lawyers Practice Leader, and FCPA Corporate Response Team Leader for the financial products division of Marsh. She is a Contributing Writer to The New York Law Journal, The Legal Times, the International In-House Counsel Journal and related legal publications. She has been interviewed by Forbes.com, Law360 and other notable internet publications. She speaks publicly and writes on a variety of insurance topics germane to all financial insurance product lines. She is a graduate of Cornell University and is admitted to practice law in New York.

Machua Millett


M. Machua Millett is the General Partner Liability Product Leader, a Claims Advocate and an FCPA Corporate Response Team Leader. He is a technical expert in insurance products relative to private equity, venture capital and alternative investment funds. Mr. Millett has over a decade of experience as an attorney for Skadden Arps, Bingham McCutchen and Edwards Angell Palmer & Dodge. He has been acknowledged as a "Rising Star in Insurance" by Reactions Magazine; a "Boston Future Leader" by the Greater Boston Chamber of Commerce; and a "Rising Star" by Massachusetts Super Lawyers Magazine. He is a graduate of Harvard Law School and is admitted to practice law in Massachusetts, Washington, D.C., and the Puerto Rico Federal District Court.

Marsh Inc


Marsh is the world's leading insurance broker and risk advisor. It teams with its clients to define, design, and deliver innovative industry-specific solutions that enable them to protect their futures and thrive. Marsh has over 24,000 colleagues who collaborate to provide guidance to clients in over 100 countries. It is a member of Marsh & McLennan Companies, a global professional services firm with 52,000 employees worldwide.

USA Anti-Corruption Insurance January 2012 Vol. 5, No. 18, Winter 2012

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