FCPA Compliance Strategies for Hedge Fund and Private Equity Fund Managers

Given today’s investment environment, with an unabated government focus on the private funds industry and significant investment opportunities in emerging markets, private fund managers are hard-pressed to ignore corruption risks in their businesses.  The Hedge Fund Law Report, The Anti-Corruption Report and law firm Molo Lamken recently hosted a panel that addressed hot topics in FCPA enforcement and compliance for the private funds industry.  The panelists, including outside and in-house counsel, discussed, among other things: the current FCPA enforcement climate for hedge fund and private equity fund managers; strategies for mitigating the risk associated with third parties and service providers in high-risk countries; handling facilitation payments; self-reporting violations; and the importance of continuous monitoring of compliance programs.  See “FCPA Considerations for the Private Fund Industry: An Interview with Former Federal Prosecutor Justin Shur,” Hedge Fund Law Report, Vol. 7, No. 20 (May 23, 2014).

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