All Things Investigations

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. This is a special series featuring sights from in-house practitioners, hosted by Mike DeBernardis. In this podcast, Mike visits with Maria Buccieri and Ashley Smith, Deputy General Counsel at Amtrak, about Encouraging and Managing Whistleblowers.

Ashley and Maria, both compliance and legal leaders from Amtrak, discuss how to encourage and manage whistleblowers as a core element of an effective compliance program, emphasizing that a lack of reports does not indicate a healthy organization. They describe a “speak-up” culture as one where employees feel heard, senior leaders model speaking up, and reporting is accessible across a diverse workforce through multiple channels (phone, email, QR codes, mobile tools, in-person availability) and languages. Key barriers include fear of retaliation (often through subtle workplace ostracism), disappointment when nothing happens, and loss of anonymity. They outline best practices for handling reports consistently with other serious complaints, preserving confidentiality “as much as possible,” training mid-level managers and investigators, and maintaining communication with reporters during lengthy investigations. They also caution against dismissing “serial reporters,” recommending contextual analysis and internal process checks.

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Resources:

Hughes Hubbard & Reed Website

Mike DeBernardis

Maria Buccieri on LinkedIn

Ashley Smith on LinkedIn

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. This is a special series featuring sights from in-house practitioners, hosted by Mike DeBernardis. In this podcast, Mike D visits with Mike Gill, Assistant GC and Director of Investigations at HII, on conducting internal investigations from an in-house perspective in a defense shipbuilding environment.

Gill says the first concern when allegations arise is immediate safety risk to employees and the integrity of work affecting Navy and other military customers, followed by designing an investigation that will be viewed as timely, accurate, and credible. He emphasizes scoping, planning, selecting the right team (including technical experts and, sometimes, outside counsel), and establishing disciplined communication and reporting lines to management and customers while protecting privilege. Gill highlights building employee trust through fair processes, enforcement of anti-retaliation policies, and appropriate follow-up, and notes common mistakes: jumping to conclusions, failing to bound scope, and inadequate planning.

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Resources:

Hughes Hubbard & Reed website

Mike DeBernardis

Mike Gill on LinkedIn

In this episode of the ATI: InHouse Insights Podcast, Mike DeBernardis speaks with seasoned in-house compliance leader Sarah Isles about navigating an ever-changing risk landscape shaped by political, geopolitical, regulatory, and technological shifts. 

Sarah shares her background across manufacturing sectors and discusses how multinational compliance risks evolve as jurisdictional priorities shift, including sanctions, export controls, tariffs, sustainability, labor rights, data protection, and AI. They identify internal challenges, including a lack of infrastructure to address new risks, siloed ownership, and weak change management, and emphasize clear governance and accountability. Sarah advises “back to basics,” using DOJ’s Evaluation of Corporate Compliance Programs, focusing on real risk mitigation over form-heavy questionnaires, keeping communication channels open through formal committees and informal connections, scaling risk assessments appropriately, targeting communications to relevant audiences, escalating thoughtfully, and building resilient programs by expecting and embracing constant change.

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Sarah Iles LinkedIn

Mike DeBernardis LinkedIn

ATI: In-House Insights Podcast

Hughes Hubbard & Reed 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 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.

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Resources:

Hughes Hubbard & Reed website

Mike DeBernardis

Welcome to the inaugural episode of the newly rebranded ATI Podcast: Inhouse Insights—formerly known as All Things Investigations.

Presented by the Hughes Hubbard & Reed LLP Anti-Corruption & Internal Investigations Practice Group, this premiere episode sets the tone for a bold new chapter—bringing practical, in-house perspectives to today’s most pressing compliance challenges.

Host Michael DeBernardis welcomes Darryl Cyphers Jr., Senior Director of Legal Compliance at Klaviyo, for a candid and forward-looking conversation on how organizations can build—and sustain—a culture of compliance that actually works.

Together, they explore how compliance leaders can move beyond policies on paper to create real organizational impact—through measurable culture metrics, smarter use of AI to drive policy engagement, authentic tone at the top, and meaningful collaboration with HR and business partners. Darryl also shares practical guidance for navigating compliance gray areas and strengthening trust through continuous employee engagement and feedback.

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Resources:

Hughes Hubbard & Reed Website

Klaviyo

Darryl Cyphers Jr. on LinkedIn

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.

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Key Takeaways for Compliance Professionals:

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.

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 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.

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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.

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Daniel Weiner

Hughes Hubbard & Reed website

HHR Client Alert: Firm Obtains Discovery Win in Dispute Over Sale of Pablo Picasso Painting