Ildefonso ‘Dito’ P Mas
Akerman, Miami and Washington, DC
Ildefonso.mas@akerman.com

Bogdan Bibicu
Wolf Theiss, Bucharest

Day one: Wednesday 17 June 2026

Opening remarks by Maximiliano D’Auro

Maximiliano D’Auro opened the conference by explaining why London, as a leading financial centre, was chosen as the location for the conference for the first time, after previous editions in Paris. He drew upon analogies to frame the conference themes: enforcement has not disappeared but has adapted, much as organisms evolve in response to threats.

Corruption, like antibiotic-resistant bacteria, finds new technologies and frameworks to utilise, and enforcement must likewise adapt. The key message was that removing corrupt actors without addressing the root causes only leads to new schemes emerging and that sustained, cross-border commitment to integrity, particularly within the global financial system, is essential.

D’Auro stressed that ‘the target keeps moving – let’s make sure we move with it’.

He also thanked the sponsors, the IBA and the Anti-Corruption Conference community.

Keynote address by Therese Chambers and Deirdre O’Mahony

Therese Chambers, Joint Executive Director of Enforcement and Market Oversight at the UK Financial Conduct Authority, delivered a speech titled ‘Beyond the headlines: the unseen fight against financial crime’, a transcript of which can be found below in the footnote text.^[1]

Panel: One year into the new Foreign Corrupt Practices Act (FCPA) regime: what has changed?

Chair
Albert B Stieglitz Jr, Alston & Bird, Washington, DC

Panellists

Brooke Daley, Warner Bros Discovery, London

Jonathan Froome, Marsh, London

Alexander J Kramer, Crowell & Moring, Washington, DC

Pallav Shukla, Trilegal, New Delhi

This panel assessed the current state of FCPA enforcement under the new United States administration. The memo issued in 2025 by Deputy Attorney General Todd Blanche, more commonly known as the ‘Blanche Memo’, has refocused the US Department of Justice’s (DOJ) priorities on transnational criminal organisations (TCOs), harm to US economic interests, national security and serious misconduct, with significantly fewer prosecutors (15, down from 30) and the US Securities and Exchange Commission (SEC) having effectively stepped back from FCPA enforcement entirely.

Despite this, panellists unanimously agreed that it is ‘business as usual’ for corporate compliance programmes: administrations change, the statute of limitations exceeds the current term and other regulators (the UK’s Serious Fraud Office (SFO), the French Financial Prosecutor’s Office (Parquet National Financier or PNF) and the World Bank) are stepping up.

The in-house panellists reported that no companies that they know of are changing their anti-bribery stance, although compliance budgets are under pressure and sales teams are testing the boundaries. ‘We have to do more with less’ was a common theme. Among other internal actions, in-house panellists also mentioned the automation of due diligence and other processes, the use of enhanced data analytics and further refining of risk mapping.

The ‘tone from the top’ remains a key driver.

The key takeaway: maintain robust compliance regardless of the enforcement cycle, because the pendulum will swing back, and the DOJ will scrutinise how companies behaved during this period.

The evolving role of financial institutions in detecting and preventing corruption

Chair
Daniel S Kahn, Davis Polk & Wardwell, Washington, DC

Panellists

Guillaume de Rancourt, Franklin, Paris

Claudia Götz Staehelin, Nater Dallafior, Zürich

Maureen Lewis, Barclays, London

Daniele Alessandro Luison, UniCredit, Milan

The panellists discussed the evolution of financial institutions from reactive participants to frontline gatekeepers in combatting financial crime.

Key themes included the tension between ‘static compliance’ (checklists) and ‘dynamic compliance’ (real-time, risk-based systems), the growing use of artificial intelligence (AI) for transaction monitoring and know-your-customer (KYC) efforts, while maintaining human oversight to avoid discrimination and ensure explainability, and the challenge of Fintech and crypto platforms operating with far less regulatory scrutiny than traditional banks.

On cooperation with regulatory authorities, the panellists noted that self-disclosure frameworks vary widely. France recently produced its first successful example of a company benefitting from voluntary disclosure, for example. In addition to this, regulators’ expectations of institutions in regard to the use of AI is rapidly increasing, even without explicit requirements governing the use of AI for compliance purposes.

The consensus was that corruption is an indirect risk for financial institutions (anti-money laundering (AML) or sanctions violations, for example), that expectations have never been higher and that the regulatory playing field between traditional institutions and new financial actors remains deeply uneven. New regulations expected to enter into force will bring additional pressure.

Following the money: the importance of beneficial ownership transparency and the tracing of illicit funds in fighting financial crime

Chair
Silvia Martina, BSVA, Milan

Panellists

Claudia Amendola, Ericsson, Rome

Marisella la Forgia, Ferrari Group, London

Viviana Mara, Leonardo, Rome

James G Tillen, Miller & Chevalier, Washington, DC

This panel brought together senior in-house compliance leaders from Ericsson, Ferrari Group (freight/logistics) and Leonardo (defence/aerospace), alongside external counsel.

The central challenge identified was the lack of a unified global beneficial ownership registry, forcing companies to rely on fragmented local registers, local intelligence providers and cross-referencing of counterparty data.

The panellists emphasised that compliance must go beyond box-checking to become an analytic discipline, involving continuous monitoring, dynamic risk assessment and corridor-based (not just country-based) thinking about risk.

Practical tips included investing in data quality, maintaining strong escalation paths for high-risk jurisdictions, ensuring the compliance department is involved from the beginning of business relationships rather than as a gatekeeper at the end and building trust between compliance and other business functions.

The defence sector panellist also stressed the importance of understanding both the client and the end user of sensitive products, while the logistics panellist noted that consistent cross-jurisdictional standards would eliminate resistance from vendors and supply chain partners.

Private equity, hedge funds, crypto and the shadow banking challenge

Chair
Eric Mayer, GSK Stockmann, Munich

Panellists

Stéphane de Navacelle, Navacelle, Paris

Alison Howell, Ericsson, Amsterdam

Puneet V Kakkar, Nardello & Co, Paris

Tomasz Konopka, Sołtysiński Kawecki & Szlęzak, Warsaw

This panel explored the risks of financial activity occurring outside the regulated banking system through private loans, crypto platforms and other channels that traditional KYC and AML controls do not reach.

The panel first provided updates on US legislation designed to address stablecoin and cryptocurrency regulation. A vivid story was also shared based on prior experience as a federal prosecutor concerning a laundering scheme that never touched a bank, using private investment advisers and non-bank loans to complete a full circle of laundering. Cryptocurrency presents similar detection and enforcement challenges.

On crypto, the collapse of Poland’s Zondacrypto exchange and its magnitude illustrated the dangers of minimal regulation, while the European Union’s Markets in Crypto-Assets (MiCA) framework (effective from 1 July 2026) represents the regulatory response to such occurrences, although enforcement capacity remains uncertain.

The panel also touched on French prosecutors’ extraterritorial reach (citing the Durov/Telegram case); the convergence of sanctions, crypto and wildlife trafficking risks at Ericsson across 180 countries; and the Norwegian sovereign wealth fund’s divestment decisions as a non-regulatory lever against bad actors.

Key takeaway: shadow banking is a strategic problem requiring a strategy based on geopolitical risk, not just legal compliance, and companies cannot sit by idly waiting for regulators to close the gaps.

Day two: Thursday 18 June 2026

Opening remarks delivered by Matthias Gstoehl

Matthias Gstoehl opened the proceedings on day two by summarising day one’s themes: divergence between US enforcement priorities and the rest of the world (particularly on environmental, social and governance (ESG)), the challenge of managing expectations on all sides and the open question of whether the pendulum will swing back, ie, to a point where the enforcement priorities of the US and those of the rest of the world are fully aligned again. Gstoehl then introduced day two’s keynote speaker and led that discussion.

Integrity compliance and its impact on the global financial system

Chair
Jodi Tuer Glasow, World Bank Group Sanctions Board, Washington, DC

Panellists

Melina Llodrá, Llodrá Law, Buenos Aires

Juan G Ronderos, Inter-American Development Bank, Washington, DC

Jamieson A Smith, World Bank Group Sanctions Board, Washington, DC

Eduardo Staino, Andrade Gutierrez, Belo Horizonte

This panel traced the arc from misconduct through investigation and sanctions to rehabilitation, focusing on World Bank and Inter-American Development Bank sanctions systems.

The key evolution has been from punitive flat debarment to conditional release tied to credible compliance reform, with the World Bank allowing a penalty reduction of up to 50 per cent for voluntary corrective action.

Panellists distinguished between ‘formal compliance’ (paper programmes) and ‘credible compliance’ (leadership buy-in, risk-tailored measures, real resource allocation, measurable key performance indicators (KPIs) and tested reporting mechanisms).

A compelling case study from Argentina involved a family-run construction company, which was initially resistant to reform, eventually finding genuine economic benefit from the development of proper procurement processes, which included the discovery of vendors who had been lying and overcharging.

Eduardo Staino shared his experience of how a three-year monitorship, with CEO-led commitment to compliance, actually improved business performance.

Key takeaway: compliance programmes must be practical, measurable and owned by the business, with the tone in the middle (not just the top) being critical for sustainable reform.

Asset recovery and restitution: the challenges of returning illicit gains to victims and states

Chair
Wendell Wong, Drew & Napier, Singapore

Panellists

Mark Morrison KC, Blake Cassels & Graydon, Calgary

Clarissa Oliveira, Oliveira Estefam Becker e Capalbo, São Paulo

Ros Prince, Stephenson Harwood, London

Nicholas Surmacz, Kobre & Kim, London

Using an Avengers-themed hypothetical about recovering billions diverted through shell companies, this panel explored the practical challenges of returning assets to victims of corruption across jurisdictions.

Key points included: (1) the US has the best tools and track record in this regard, but such an approach requires enormous resources; (2) governments’ self-interest often conflicts with cross-border restitution; (3) banks generally cooperate in returning frozen funds because they do not want to be exposed to litigation; and (4) organised restitution funds, while theoretically attractive, create complex administration and competing claims.

The Boeing case illustrates how victim identification itself can be contested. The panellists agreed that going down the criminal route means losing control, that the documentation of decision-making is essential and that ‘sunlight is the best disinfectant’, particularly the disclosure of where money goes, combined with democratic accountability, which produces better outcomes than centralised fund administration.

The recovery of funds for victims has been and remains a complicated issue that requires claimants to aggressively seek recourse through civil litigation and criminal restitution, where those options are available. Other examples from legal practice were discussed by the panellists.

The geopolitics of anti-corruption: sanctions, trade and influence

Chair
Andrew M Levine, Debevoise & Plimpton, New York

Panellists

Adriana Dantas, Lefosse Advogados, São Paulo

Vincenzo Dell’Osso, BonelliErede, Milan

Jo Morgan, Sandvik Group, Stockholm

Kathleen Shannon, Boies Schiller Flexner, Washington, DC

This panel examined whether sanctions have become a dominant enforcement tool, surpassing traditional anti-corruption mechanisms.

The consensus from an audience poll was that most companies are not adequately prepared for the convergence of anti-corruption, sanctions, national security and geopolitical risks.

Key practical challenges included: (1) full compliance with all of the applicable sanctions regimes across jurisdictions is effectively impossible; (2) secondary sanctions create ‘sanctionable’ activity even without the occurrence of violations; (3) recent judgments, for example, the ruling by the Court of Justice of the European Union that specially designated nationals (SDN) listing alone is insufficient grounds for banks to deny access to the provision of accounts; and (4) the weaponisation of sanctions has intensified through the use of Magnitsky designations and tariffs justified by alleged anti-corruption failures.

Panel members also mentioned that sanctions represent an instrument to be used when a government enforcement agency wants an immediate result.

The compliance officer from a mining equipment company highlighted the challenges of sanctions compliance in light of the lack of control over certain aspects of the business, for example, where small cutting tools sold by a company might end up.

The panel members agreed that while anti-corruption clauses are more easily included and accepted in contracts, sanctions compliance-related clauses are more strongly resisted and more intensely negotiated.

Final recommendations: (1) develop a geopolitical risk strategy (not just legal compliance), (2) document decisions thoroughly, (3) review risk matrices regularly and (4) bear in mind that companies are increasingly asking external counsel to advise on political matters affecting sanctions enforcement that may go beyond traditional legal advice.

The practitioners’ corner: defending corporations and individuals in global anti-corruption trials

Chair

Juliana Maia Daniel, Berardo Advogados, São Paulo

Panellists

Duncan Grieve, Signature Litigation, London

Kateryna Gupalo, Arzinger, Kyiv

Steve Holt, Grant Thornton, London

Jessica Parker, Corker Binning, London

Armando Simbari, Simbari Avvocati, Milan

This panel addressed the practical challenges when conducting internal investigations and defending corporations facing enforcement action globally.

A panellist from the UK noted that while the US has historically led in terms of enforcement, the priorities have shifted and she is not optimistic about a return to prior enforcement levels in the US or the UK.

Panel members also discussed the different level of privilege protection, if any, among various jurisdictions, which may significantly impact companies and their approach to anti-corruption investigations or trials. The panellists recommended that external counsel, investigators and companies should consider structuring or addressing legal privilege issues at the beginning of any investigation or representation. Recent SFO cases and reports by the Organisation for Economic Co-operation and Development (OECD) regarding anti-corruptions matters were also highlighted and discussed by the panellists.

Key discussion points included: (1) the fragility of legal privilege across jurisdictions (privilege can inadvertently be waived during discussions with auditors); (2) the importance of forensic investigators keeping language ‘tight, straightforward and boring’ because a company loses control of written documents once they have been produced, in other words assume that such documents will be read by other actors and/or regulatory authorities; and (3) there is a risk that internal investigations could be ‘sterilised’ or used as evidence in subsequent proceedings.

The panel emphasised that documenting business actions to show that a sensible, proportionate and reasonable process took place is important and that careful consideration should be given to how facts are presented to the outside world.

Closing remarks by Deirdre O’Mahony

Deirdre O’Mahony closed the conference by noting that a running theme across all the panels was that anti-corruption professionals are working with clients during a period of enormous change that is occurring at an unprecedented pace, making London the fitting location for such discussions.

She highlighted the involvement of top-class industry professionals, regulators and chief compliance officers, particularly the discussion that took place with the General Counsel of UBS, and reiterated the strongest message of the conference: corruption requires a response from the whole system, requiring cooperation between regulators, prosecutors, financial systems and other relevant actors and for that cooperation to occur across borders.