Welcome back to the podcast, bribe, swindle, or steel. I'm Alexandra Rogge, and today we're

talking about the first 48 hours after you learn that a bribe may have been paid. My guest today

is Nat Edmonds. Nat is a partner with Paul Hastings, where he serves as the chair of the

firm's litigation practice in Washington, D.C. Prior to joining the firm, he was the assistant

chief of the FCPA unit of the fraud section in the criminal division at the Department of Justice.

Nat's practice now focuses on global internal investigations, specializing in anti-corruption matters, and the challenges

associated with multi-jurisdictional investigations into complex economic crime.

Nat, thanks so much for joining me.

My pleasure.

Happy to be here.

You are the right person for this topic, so I'm just going to turn this over to you and let

you talk us through those first 48 hours. Well, those first

48 hours can be absolutely excruciating. So I want to share a little bit of the wisdom that I've

gained in the 15 or so years that I've been doing SCPA investigations on both sides, first with

the Department of Justice and now working with Paul Hastings and

advising both large and small companies around the world. The most important thing is to not panic.

To paraphrase a very old science fiction, a phrase, don't panic. This is not the time to get lost in what may happen. This is the time to focus

very specifically on a couple important things to do in the first 24 hours. And the first thing

you have to do is to stop the payments. Once you've determined that a bribe has been paid,

the key thing is to make sure that no further money goes out of the company.

I will come back to that in a moment.

But the next thing you have to do is you have to preserve the data, ensure that there is no possibility of data destruction,

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