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Enforcement Edge
October 28, 2021

At ABA Conference, Top FCPA Enforcer Talks Women in White Collar

Enforcement Edge: Shining Light on Government Enforcement

At the 36th annual ABA White Collar Crime Conference, this year also marked the 4th annual Women in White Collar Lunch, which featured a Q&A with Lorinda Laryea, Principal Assistant Chief of the DOJ Fraud Section’s Foreign Corrupt Practices Act (FCPA) Unit. Laryea discussed the importance of gender and racial diversity in white collar criminal work, as well as international cooperation in foreign corruption cases, the rising use of non-email communications by company employees, and the future of government investigations in a post-COVID world.

Laryea began by acknowledging the gender and racial diversity challenges in the white collar enforcement space. In giving advice from her own career experience, she noted that “your mentors don’t have to look like you.” The handful of men at the Women in White Collar lunch seemed to agree, recognizing the role men play in furthering gender equality. Laryea emphasized the value to her career of clerking for federal judges, especially for those clerks interested in becoming federal prosecutors. She discussed certain challenges unique to women as well as challenges universal to all parents, such as navigating child care in the face of never-ending Zoom meetings during the pandemic. Cultivating this gender and racial diversity is paramount, she explained, as companies need to hear a diversity of perspectives and juries also respond better to more diverse trial teams.

Laryea also shared her views from her significant experience prosecuting foreign corruption cases. While FCPA prosecutors used to rely on the notoriously slow MLAT process, less formal international cooperation now is key, as enforcers throughout the world have come to recognize the benefits and efficiencies of talking to each other and sharing evidence in an iterative fashion. She also highlighted the government’s use of data analytics in detecting, investigating, and prosecuting white collar crime. As we have discussed before, companies face a new challenge of preserving, collecting, and sometimes even producing huge volumes of non-email communications in text messages and on the latest encrypted and ephemeral messaging apps that their employees choose to use. She expressed her hope that, as the government gradually shifts back to working in person, investigators and prosecutors will utilize a hybrid approach to the in-person versus virtual question. As she noted, prosecutors learned during the pandemic that they efficiently could interview a witness in Europe in the morning and a witness in Brazil in the afternoon.

We look forward to hearing more from Laryea and other prominent female government attorneys, including Deputy Attorney General Lisa Monaco, later in the conference. Check back here for more!

© Arnold & Porter Kaye Scholer LLP 2021 All Rights Reserved. This blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.