Navigating Compliance Challenges in Venezuela’s Energy Sector

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Mike DeBernardis to discuss the implications of entering Venezuela for energy companies and the historical precedents. They explore the return of US energy companies to the Venezuelan market and historical precedents, such as the Iraq Oil-for-Food Program, post-2003 Iraq, and the 1990s Russian market opening, to identify the risks and the necessary compliance measures. Key insights include the importance of stringent third-party controls, understanding the nuances of dealing with state-owned entities such as PdVSA, and having a robust risk management strategy. The conversation underscores the critical need for compliance professionals to thoroughly understand business operations to build effective compliance programs in high-risk environments. Key highlights: Challenges and Opportunities in Venezuela Historical Parallels: Iraq Oil for Food Program Lessons from Post-2003 Iraq Comparing Venezuela to 1990s Russia Counseling Clients on High-Risk Opportunities Resources: Hughes Hubbard & Reed website Mike DeBernardis

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, Michael DeBernardis hosts Darryl Cyphers Jr., the Senior Director of Legal Compliance at Klaviyo, to discuss the importance of corporate culture. They delve into the importance of establishing a culture of compliance within an organization and discuss strategies to achieve it. Key topics include the metrics used to assess compliance culture, the benefits of using AI for policy engagement, the importance of tone at the top, and the need for collaboration with other departments, such as HR and business units. Darryl also shares practical tips for managing gray areas in compliance and emphasizes the value of regular employee engagement and feedback. Highlights include: Defining Culture of Compliance Metrics and Tools for Compliance Employee Engagement and Feedback Building Partnerships Across Departments Innovative Training Approaches Navigating Gray Areas in Compliance Resources: Hughes Hubbard & Reed Website Klaviyo Website

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast All Things Investigation. In this podcast, host Tom Fox welcomes back Sean Riley to discuss the complexities of tariffs under the current administration.   Their conversation highlights the dynamic nature of tariff regimes, the importance of maintaining compliance, and the risks of tariff evasion. Sean provides insights into creating effective tariff compliance programs, the potential for False Claims Act liabilities, and the critical role of commercial sense in assessing tariff changes. The episode also touches on enforcement priorities and the strategic importance for boards of directors to remain vigilant about tariff-related risks. As the discussion moves towards the evolving landscape leading into 2026, Sean emphasizes the importance of staying informed and prepared for ongoing tariff regulations.  Highlights Include  ·      Compliance and Enforcement in Tariff Management ·      Commercial Sense in Tariff Decisions ·      Board Oversight and Tariff Compliance ·      Future of Tariffs and Compliance Going Forward  Resources: Hughes Hubbard & Reed website  Sean Reilly

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Jeremy Paner and Diego Durán de la Vega to discuss recent FinCEN enforcement actions targeting three Mexican financial institutions. The conversation explores the implications of these actions under the Fend Off Fentanyl Act, the evolving regulatory landscape, and the existential risks facing financial institutions operating in Mexico. The guests provide practical compliance guidance, lessons learned, and a forward-looking perspective on U.S. enforcement trends. Highlights include: Why These Enforcement Actions Matter The Fend Off Fentanyl Act: A New Legal Tool U.S. Government Focus on Mexico Lessons from OFAC Enforcement Compliance Implications for Financial Institutions Responding to Enforcement: Practical Steps Global Jurisdiction and the U.S. Financial System Key Lessons for Compliance Officers Looking Ahead: Future Enforcement Trends Key Takeaways for Compliance Professionals: The Fend Off Fentanyl Act introduces new, immediate risks for financial institutions, especially those with ties to Mexico. U.S. enforcement actions can have global reach, severing access to the U.S. financial system. Compliance programs must be robust, proactive, and responsive to regulatory advisories and negative media. Effective communication between compliance and legal functions is crucial for mitigating risk. Resources: Hughes Hubbard & Reed website Jeremy Paner Diego Durán de la Vega

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Mike DeBernardis to discuss the recently released first Foreign Corrupt Practices Act (FCPA) enforcement action, a Declination involving Liberty Mutual Insurance Company. Mike DeBernardis, partner at Hughes Hubbard & Reed, and Tom delve into the first FCPA enforcement action of 2025 involving Liberty Mutual. They discuss the nuances of self-disclosure during ongoing investigations, the challenges facing defense attorneys, and the expectations set by the new corporate enforcement policy. Key topics include proactive cooperation, dealing with deconfliction, and the importance of root cause analysis. The conversation provides valuable insights into how the Department of Justice communicates its expectations through enforcement actions and the evolving landscape of corporate compliance. Key highlights: Exploring the Liberty Mutual Case Challenges of Early Self-Disclosure Corporate Enforcement Policy Changes Full and Proactive Cooperation De-confliction in DOJ Investigations Root Cause Analysis Importance Social Media and Ephemeral Messaging  Resources: Hughes Hubbard & Reed website Mike DeBernardis

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR partner Mike Huneke and BRG Director Brent Carlson to discuss secondary tariffs. Mike Huneke and Brent Carlson are leading experts in trade compliance, with a particular focus on the intricacies and impacts of tariffs and secondary tariffs within the global economic landscape. Huneke emphasizes the existential threats tariffs pose to businesses, stressing the importance of understanding their effects on countries with significant economic ties to Russia, such as China, and advising companies to reassess trade relationships with nations like China, Brazil, Russia, and Iran. Carlson emphasizes the need for trade compliance officers to adapt to the rapidly evolving geopolitical landscape, advising companies to assess their suppliers and consider potential indirect transactions through transshipment countries to navigate imposed tariffs effectively. Both experts emphasize the importance of businesses adopting a dynamic, risk-based approach to compliance, anticipating challenges, and making informed decisions to mitigate financial impacts and maintain shareholder value amid shifting trade patterns and geopolitical tensions. Key highlights: Geopolitical Impact of Secondary Tariffs Global Trade Dynamics Amid Geopolitical Shifts Trade Compliance Risks: False Claims & Tariff Evasion Resilient Supply Chain Strategy Amid Global Trade Dynamics Negotiating Tactics in Geopolitical Tariff Strategy Resources: Mike Huneke Hughes Hubbard & Reed Website Brent Carlson BRG Website

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by Daniel Weiner to discuss a complex legal case involving a valuable Picasso painting. Weiner is the Chair of Hughes Hubbard & Reed’s Litigation Department, Chair of the Complex Business Disputes practice, and a partner in the International & Domestic Arbitration and Intellectual Property Disputes groups. Daniel and Tom take a deep dive into the intricate details of how a series of fraudulent transactions led to a multimillion-dollar dispute over Picasso’s ‘Le Peintre.‘ The podcast highlights the importance of thorough due diligence in the art world and examines the legal complexities involved in resolving such cases. As they unravel the story, they highlight the crucial role of investigations in preventing art fraud and safeguarding ownership rights. Key highlights: The Fascinating Picasso Case The Fraud Unveiled Legal Issues and Investigations Discovery Disputes and Court Proceedings Consulting and Due Diligence in Art Law Resources: Daniel Weiner Hughes Hubbard & Reed website HHR Client Alert: Firm Obtains Discovery Win in Dispute Over Sale of Pablo Picasso Painting

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this episode of ‘All Things Investigations,’ host Tom Fox is joined by Mike DeBernardis to discuss the recent guidelines released by Deputy Attorney General Todd Blanche on the enforcement of the Foreign Corrupt Practices Act (FCPA). They dissect the new memorandum, its implications for corporate investigations, and the focus on eliminating cartels and transnational criminal organizations. The conversation also delves into topics such as competitive advantage, the role of national security in FCPA enforcement, and the strategic implications for companies. The episode concludes with insights on how companies and their legal counsel should navigate these updated guidelines and prepare for a more expedited and focused investigation process. Key highlights: Overview of New FCPA Guidelines Focus on Competitive Advantage Prosecutorial Considerations National Security and Strategic Business Prioritizing Serious Misconduct Advising Clients on FCPA Compliance Resources: Mike DeBernardis Hughes Hubbard & Reed website HHR Client Alert: DOJ Ends FCPA Enforcement Pause

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR lawyers Mike DeBernardis and Katherine Taylor about the recent speech by Matthew R. Galeotti, Head of the Criminal Division at the U.S. Department of Justice (DOJ);  his attendant Memo entitled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime; and the updates to the Corporate Enforcement and Voluntary Self-Disclosure Policy; and finally the new Memo on Monitors and Monitorships. Key highlights: Is meaningful cooperation credit finally here? Did we move from a presumption of a declination to something stronger or at least more tangible? Is the Kenneth Polite “double secret—we know it when we see it” cooperation requirement now a thing of the past, or at least defined? Enhancements to the Whistleblower Program—Initial Thoughts. Monitors—dead and gone or something else? What, if anything, does this change about the role of corporate compliance today? Resources: Mike DeBernardis Hughes Hubbard & Reed website Katherine Taylor

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR lawyers Mike DeBernardis and Sean Reilly to discuss the new HHR Task Force. In this award-winning All Things Investigations podcast episode, host Tom Fox converses with Hughes Hubbard and Reed partners Mike De Bernardis and Sean Reilly about the firm’s strategic reorganization. Responding to the U.S. administration’s fresh focus on cartels and foreign terrorist organizations, Hughes Hubbard has built a cross-disciplinary task force. This team combines expertise from compliance, sanctions, and dispute resolution practices to address companies’ heightened risks and compliance obligations, particularly in Mexico and Latin America. The discussion also covers implications for multinational corporations, the importance of reassessing risk, how the administration’s prioritization of certain enforcement actions can influence corporate strategies, and the emerging dangers surrounding tariffs and the False Claims Act. Key highlights: Hughes Hubbard’s New Task Force Implications of Cartel Designations National Security and Voluntary Disclosure Cross-Functional Task Force Benefits Tariff Evasion and False Claims Act Resources: Mike DeBernardis Hughes Hubbard & Reed website Sean Reilly