FCPA Enforcement in 2011:
China in the Spotlight

23 Mar 2011 11:30 a.m. - 02:00 p.m.

Crowne Plaza Cabana
4290 El Camino Real
Palo Alto, CA 94306
Palo Alto Events
(650) 813-5746

Morrison & Foerster and Markkula Center for Applied Ethics Seminar Series.

Why is the SEC’s San Francisco office home to a unit devoted to Foreign Corrupt Practices Act (FCPA) enforcement? Tracy Davis, the unit’s head, has explained: “The fact that we have a significant presence of companies in Silicon Valley who do business internationally, specifically in Asia, makes us well-suited for addressing these kinds of issues.”

Silicon Valley companies who do business in Asia—especially China—are in the government’s spotlight. And the government has backed up its tough talk with action. Since 2002, business activities in China have given rise to nearly 40 FCPA enforcement actions, more than almost any other country.

Please join us for a discussion of the FCPA challenges faced by Silicon Valley companies doing business in China, why the government scrutinizes business practices there, and practical compliance solutions.


  • FCPA compliance challenges in the PRC 
  • Bringing your code of business conduct to China 
  • Avoiding problems with joint venture partners and third-party agents 
  • Dealing with state-owned enterprises (SOE) 
  • Determining who is a government official in China 
  • Conducting proper due diligence in China 
  • Hosting government officials 
  • Special risks of conducting internal investigations in China 
  • Whether to self-report an FCPA violation to the U.S. government


  • Tracy L. Davis
    Assistant Regional Director
    SEC FCPA Unit, San Francisco 
  • Paul T. Friedman
    Partner, Morrison & Foerster 
  • Kirk Hanson
    Executive Director
    Markkula Center for Applied Ethics 
  • Joe Zier
    Partner, Deloitte Financial Advisory Services LLP


  • Craig D. Martin
    Partner, Morrison & Foerster

MCLE Language Morrison & Foerster LLP (Provider #2183) certifies that
this activity has been approved for MCLE credit by the State Bar
of California in the amount of 1.5 hours, of which 0.5 hours will
qualify for ethics credit.




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